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D.B. Pleschner: Is court the right place to determine ‘best available science’?

February 12, 2018 — A U.S. District Court judge recently ruled that the federal government’s catch limit for California’s central stock of anchovy — currently 25,000 metric tons — is far too high.

But instead of weighing all the facts, the judge ignored them, shunned the established precedent of deference to federal agencies’ scientific determinations and instead endorsed the flawed arguments of the advocacy group Oceana.

So what happened?

It’s a well-accepted fact that the anchovy population on the West Coast has extreme natural variations in abundance, even without fishing. To account for these wild swings, scientists reduced the overfishing limit of 100,000 tons by 75 percent, setting the annual catch limit at 25,000 metric tons. The Pacific Fishery Management Council’s Science and Statistical Committee approved the numbers as “best available science” and the National Marine Fisheries Service agreed, recognizing that the anchovy resource ranges from peaks of more than two million tons to orders of magnitude lower and quickly jumps back up again.

In California, the anchovy fishery declined in the 1980s due to adverse market conditions and landings have averaged less than 10,000 tons a year ever since. But this fishery is still important because it keeps the local fleet on the water and processing plant doors open when no other fish are available.

Regardless, environmentalists began lobbying the council in 2015 to curtail California’s anchovy catch limit after one advocacy group funded a new research paper that reassessed the basis for anchovy management — a 1991 study based on egg and larval data that represented long-term average biomass abundance, not a single-year stock assessment. Because the reassessment had virtually no adult anchovy biological data from recent years to correlate, the authors had to make assumptions. They concluded that the anchovy population had collapsed, with current biomass estimated at only about 15,000 tons coast-wide.

But other scientists challenged the findings, in part because the new estimate excluded Mexico where a substantial portion of the stock resides, and it also omitted nearshore waters where fishermen were reporting masses of anchovy.

Richard Parrish, retired from NMFS after decades of experience with anchovy, critiqued the paper and stated, “The biomass estimates in the paper cannot be used to estimate the 2016 biomass of the northern stock of anchovy…” He continued, “Clearly, with northern anchovy a five-year-old biomass estimate is not significantly better at estimating current biomass than a 25-year-old biomass estimate.” That statement was included in the Administrative Record (AR) for the Oceana lawsuit, but the judge ignored it.

In 2016, the council sponsored a data-poor workshop where internationally recognized scientists reviewed the new egg-larval analysis along with other available data and also rejected the study’s findings. As one member said, “The estimate did not pass the straight face test.”

Here’s why: the new assessment did not consider anchovy fishery landings, which in 2015 totaled about 64,000 tons, only 17,000 tons in California (still under the 25,000 ton catch limit) and the rest from Mexico. As Parrish pointed out, “Clearly, the absolute minimum biomass estimate for 2015, assuming that the fishery caught every last anchovy in the population, would be 64,114 tons. If fishermen took 50 percent of the biomass, based on recorded landings, the estimate would be 128,000 tons and if they took only 20 percent of the biomass, the estimate would be 320,000 tons, massively above the study’s assertions.”

Read the full opinion piece at the Santa Cruz Sentinel 

 

D.B. Pleschner: Nearshore anchovy abundance not proof fishery is collapsing

November 2, 2017 — Recently, Dr. William Sydeman of the Farallon Institute, published a study claiming that the abundance of anchovy near shore — especially in places like Monterey — is evidence that the population is collapsing.

Sydeman’s logic is based on an old argument that collapsed populations always shrink inshore. But there’s one big problem with that theory — it’s unsupported by scientific evidence. In fact, that logic was based on an old sardine theory that has since been debunked. There’s certainly no evidence that low anchovy biomass results in an increase in anchovy in the nearshore area of Central California.

In fact, the opposite is likely true. According to the Monterey Herald, the anchovies that flooded into Monterey Harbor in September were 3 inches long. Pete Guglielmo, an anchovy processor in Monterey, exclaimed, “Inside Monterey harbor and the outer break wall, you can walk on 3-inch anchovy. What a sight to see! They are running the air pumps in the harbor to keep them alive.”

In other words, the abundance of 3-inch (young-of-the-year) anchovy in the nearshore region implies that there is a strong 2017 year-class. A record abundance of young-of-the-year also was documented in scientific cruises going back to 2015, as well as observed by fishermen in both northern and southern California.

Read the full story at the Monterey Herald

 

D.B. Pleschner: Study: No correlation between forage fish, predator populations

April 10, 2017 — On April 9-10, the Pacific Fishery Management Council is meeting in Sacramento to deliberate on anchovy management and decide on 2017 harvest limits for sardine, two prominent west coast forage fish.

Extreme environmental groups like Oceana and Pew have plastered social media with allegations that the anchovy population has crashed, sardines are being overfished and fisheries should be curtailed, despite ample evidence to the contrary.

Beyond multiple lines of recent evidence that both sardines and anchovy populations are increasing in the ocean, a new study published this week in the journal Fisheries Research finds that the abundance of these and other forage fish species is driven primarily by environmental cycles with little impact from fishing, and well-managed fisheries have a negligible impact on predators — such as larger fish, sea lions and seabirds.

This finding flies directly in the face of previous assumptions prominent in a 2012 study commissioned by the Lenfest Ocean Program, funded by the Pew Charitable Trusts, heirs of Sun Oil Company. The Lenfest study concluded that forage fish are twice as valuable when left in the water to be eaten by predators and recommended slashing forage fishery catch rates by 50 to 80 percent.

However, in the new study, a team of seven internationally respected fisheries scientists, led by Prof. Ray Hilborn, Ph.D., of the University of Washington, discovered no correlation between predator populations and forage fish abundance. The new research also found multiple omissions in the methodology of the Lenfest study. For instance, it — and other previous studies — used ecosystem models that ignored the natural variability of forage fish, which often fluctuate greatly in abundance from year-to-year.

Read the full opinion piece at the Santa Cruz Sentinel

D.B. PLESCHNER: Why Does President Obama Want to Eliminate Sustainable Commercial Fisheries?

August 29, 2016 — SEAFOOD NEWS — Dear Seafood News Editor,

“Help us identify Champions who are helping the ongoing recovery of America’s fishing industry and fishing communities,” Secretary of Commerce Penny Pritzker and Council of Environmental Quality Director Christy Goldfuss posted on the White House Blog on August 10.   They were appealing for nominees for this year’s White House Champion of Change for Sustainable Seafood.”

The blogpost had many complimentary things to say about our U.S. commercial fisheries:

“America’s fishers, and our seafood industry, have fed Americans and their families since our nation’s beginning. What’s more, this industry remains critical to the economic health and well-being of communities across the country.

“After decades of decline, we are witnessing the economic and ecological recovery of America’s fishing industry.  Overfishing has hit an all-time low, and many stocks are returning to sustainable levels. The U.S. fishing industry contributed nearly $200 billion annually to the American economy in 2014 and supports 1.7 million jobs.

“This shift did not come easy.  It took hard work, collaboration, and sacrifice by many across the country. Although there’s still more to do, America’s fisherman have led the way to the United States becoming a global leader in sustainable seafood management.

“This turnaround is a story about innovative ways to catch fish and other seafood sustainably, and connect fishers with their customers. It is a story about the value of science and management working together, and a willingness to make sacrifices today for a better tomorrow. And it is a story about sustaining a proud livelihood that is the backbone of so many coastal communities nationwide.

“President Obama and his Administration want to honor America’s fishers and our coastal communities for their efforts.”

We agree with everything Secretary Pritzker and Director Golfuss said.

Yet on Friday, August 26, President Obama announced he was expanding the Papahānaumokuākea Marine National Monument off the coast of Hawaii, creating the world’s largest marine protected area. The fact sheet stated:  “Building on the United States’ global leadership in marine conservation, today’s designation will more than quadruple the size of the existing marine monument, permanently protecting pristine coral reefs, deep sea marine habitats, and important ecological resources in the waters of the Northwest Hawaiian Islands.”

But President Obama’s executive order, authorized under the Antiquities Act, also prohibited commercial fishing in an area increased by 442,781 square miles, bringing the total protected area of the expanded monument to 582,578 square miles.   This unilateral action happened without the transparency, science-based decision-making and robust public process trumpeted in the President’s own National Ocean Policy, nor the bipartisan Congressionally mandated Magnuson Stevens Fishery Conservation and Management Act (MSA), which requires fisheries to be managed under a transparent, science-based process administered by regional fishery management councils.

The announcement precipitated extreme disappointment from commercial fishermen and Council members alike, who decried the lack of science and economic pain inflicted on sustainable fisheries and fishing communities. “Closing 60 percent of Hawaii’s waters to commercial fishing, when science is telling us that it will not lead to more productive local fisheries, makes no sense,” said Edwin Ebiusi Jr., chair of the Western Pacific Fishery Management Council.  “Today is a sad day in the history of Hawaii’s fisheries and a negative blow to our local food security.”

“It serves a political legacy rather than any conservation benefits …” said Council Executive Director Kitty Simonds.  “The campaign to expand the monument was organized by a multibillion dollar, agenda-driven environmental organization…  The President obviously chose not to balance the interests of Hawaii’s community, which has been divided on this issue,” she added.  Fisheries are the state’s top food producer, according the Hawaii Department of Agriculture.

“Our party’s over,” wrote Sean Martin, president of the Hawaii Longline Association, but the monument lobbying effort continues on the east coast and off California, where well-heeled environmental advocates are lobbying to close productive sea mounts in New England, as well as most of the offshore seamounts, banks and ridges off the California coast, all of which are critically important to the long-term sustainability of commercial fisheries in those regions.

On both the east and west coast, fishermen, allied seafood companies and business interests as well as the regional fishery management councils have mounted vigorous opposition to the use of unilateral executive order under the Antiquities Act to manage fisheries.   They point to existing National Ocean Policy promises and the Magnuson Act, which require science-based decision-making and robust stakeholder involvement.  A transparent process that includes scientific and economic analysis and public involvement already exists through the MSA and fishery management councils.    Why not use it?

This Administration’s disrespect for Congressional mandate and its own ocean policies begs the question:  Why does this President want to curtail sustainable fisheries?

D.B. Pleschner
Executive Director
California Wetfish Producers Association

This letter originally appeared on Seafoodnews.com, a subscription site. It is reprinted with permission.

D.B. PLESCHNER: Monument proposal would devastate California’s fishing industry

August 15, 2016 — The following is excerpted from an opinion piece written by D.B. Pleschner, executive director of the California Wetfish Producers Association. It was published today in the Sacramento Bee:

California’s fisheries provide healthy, sustainable food, but that could change under a dangerous new proposal being circulated, until recently, behind closed doors at the Legislature.

California’s fishing community – more than 40 harbors, chambers of commerce, seafood processors and recreational and commercial fishing groups – has united to oppose the proposal to declare virtually all offshore seamounts, ridges and banks off the coast as monuments under the Antiquities Act and permanently close these areas to commercial fishing.

After pursuing rumors, fisheries groups discovered the proposal, along with a sign-on letter encouraging legislative support. But no one bothered to seek any input from recreational and commercial fishermen. Even worse, there has been no scientific review or economic analysis, no public participation and no transparency.

The areas identified in the proposal are indeed special places, rich in marine life and valuable corals, sponges and structures. The seamounts and banks are also very important for fisheries.

Tuna, swordfish, rockfish, spiny lobster, sea urchins, white sea bass and species including mackerels, bonito and market squid are all sustainably fished in Southern and Central California. And in Northern California, albacore tuna and other species provide opportunities to fishermen who, for the past few seasons, have been unable to rely on Chinook salmon and Dungeness crab.

These areas do deserve protection. But policies for protecting resources in federal waters exist under the federal Magnuson-Stevens Fishery Conservation and Management Act and other bipartisan laws, such as the Marine Mammal Protection Act and Endangered Species Act, which require science-based, peer-reviewed analysis conducted in a fully public and transparent process.

Read the full opinion piece at the Sacramento Bee

Alaska’s $10 Million Cut to its Fisheries Budget Expected to Ripple Across the Commercial Industry

April 26, 2016 — SEAFOOD NEWS — The $10 million cut to Alaska’s fishery budget for the 2017 fiscal year is expected to have widespread ramifications for the state’s commercial industry.  Last year’s budget cuts resulted in 109 fishery projects getting axed. Now another 65 are on the cut list for the upcoming fiscal year that begins on July 1. The slimmer budget means resources are more limited for fishery stock surveys and scientific research in addition to other fishery management needs.  “With cuts of that magnitude, everything is on the table,” said Scott Kelley, director of the Commercial Fisheries Division at the Dept. of Fish and Game.

We ran an opinion piece from D.B. Pleschner, the Executive Director of the California Wetfish Producers, that points to the recent scientific evidence that suggests West Coast sardine stocks are actually rebuilding. Pleschner writes how recent recruitment reports show the fishery’s young fish stocks are trending very close to how they looked prior to the 2007 population peak.  She also discusses how these scientific findings have gained little attention from the media and NGOS, who have instead blamed overfishing and lack of management for the stock’s declines.

In other news, China added lobster, crab and coldwater shrimp imports to a list of E-commerce items that are eligible for expedited cross-border clearance and lower taxes. The list an effort by China to reduce the cross-border tax paid by consumers, and to close a loophole that allowed parcel shipments to avoid taxes when resold, for instance, when they are imported by wholesalers.

Vietnam expects a 12 percent hike in exported shrimp revenues to push its overall earnings in seafood shipments past $7 billion this year. Shrimp is on track to account for about half of this year’s earnings.

Finally, Vinh Hoan will debut a line of untreated, premium pangasius fillets to the market at its booth number 5-553 during the Seafood Expo Global in Brussels this week. “People today want more natural food options with minimal processing and our untreated Premium Pangasius fillets provide that along with a delicious dining experience,” said Nguyen Ngo Vi Tam, Vinh Hoan Sales and Marketing Director. “With Vinh Hoan’s long-established commitment to sustainable practices, it just makes sense we would lead the way with this untreated option.”

This story originally appeared on Seafoodnews.com, a subscription site. It is reprinted with permission.

D.B. PLESCHNER: Recent Fishery Study Debunked by 1,400 Years of Data

September 2, 2015 — The following op-ed by D.B. Pleschner was submitted to Saving Seafood:

In an article in International Business Times (August 5, 2015), Aditya Tejas quoted researcher Malin Pinsky in his recently published paper that claims smaller, faster-growing fish like sardines and anchovies are more vulnerable to population collapses than larger fish.

“Climate variations or natural boom-and-bust cycles contribute to population fluctuation in small fast-growing fish,” Pinsky said, “but when they are not overfished, our data showed that their populations didn’t have any more tendency to collapse than other fish.” He called these findings counterintuitive because the opposite dynamic holds true on land: “Mice thrive while lions, tigers and elephants are endangered,” he said.

While it’s common these days to blame the ocean’s woes on overfishing, the truth is Pinsky’s conclusions don’t paint a complete picture. Fortunately, we do have an accurate picture and it’s definitely better than the proverbial thousand words.

The picture is a graph (adapted from Baumgartner et al in CalCOFI Reports 1992, attached) that shows sardine booms and busts for the past 1,400 years. The data were extracted from an anaerobic trench in the Santa Barbara Channel which correlated sardine and anchovy recoveries and collapses with oceanic cycles.

It’s important to note that most of sardine collapses in this timeframe occurred when there was virtually no commercial fishing. The best science now attributes great fluctuations and collapses experienced by sardines to be part of a natural cycle.

“Pinsky has never been a terrestrial biologist or naturalist or he would have known that small rodents have boom and bust cycles brought about by combinations of environmental conditions and the mice’s early maturity and high fecundity rates,” says Dr. Richard Parrish, an expert in population dynamics now retired from the National Marine Fisheries Service, .

“All fish stocks show boom and bust cycles in recruitment unrelated to fishing,” says Dr. Ray Hilborn, internationally respected fisheries scientist from the University of Washington. “Sardines in particular have been shown to have very great fluctuations and collapses long before commercial fishing. Fast growing, short-lived species will be much more likely to decline to a level called “collapse” when recruitment fluctuates because they are short lived — longer lived species won’t decline as much.”

As a further poke in the eye to the truth, Pinsky cites sardines off the coast of Southern California as a species that has seen fluctuations for thousands of years, but “not at the levels that they’ve experienced in recent decades due to overfishing.”

Again, this simply is not true.

Since the fishery reopened in 1987, Pacific sardines have been perhaps the best-managed fishery in the world – the poster fish for effective ecosystem-based management. The current harvest control rule, updated to be even more precautionary in 2014, sets a strict harvest guideline that considers ocean conditions and automatically reduces the catch limit as the biomass declines.

If the temperature is cold – which scientists believe hampers sardine recruitment – the harvest is reduced. And if the population size declines, both the harvest rate and the allowable catch will automatically decrease, and directed fishing will be stopped entirely when biomass declines below 150,000 mt.

In fact, the current sardine harvest rule is actually more precautionary than the original rule it replaced. It does this by producing an average long-term population size at 75 percent of the unfished size, leaving even more fish in the water, vs. 67 percent in the original rule. The original harvest rule reduced the minimum harvest rate to 5 percent during cold periods. The present has a minimum rate of 0 percent during cold periods.

Compare this to the 1940s and ’50s when the fishery harvest averaged 43 percent or more of the standing sardine stock with little regulatory oversight and no limit on the annual catch. This, coupled with unfavorable ocean conditions, culminated in the historic sardine fishery collapse that devastated Monterey’s Cannery Row.

But that was nearly 70 years ago, not “recent decades.” Our current fishery harvest is less than a quarter of the rate observed during that historical sardine collapse.

As a scientist, Pinsky should be aware of the complex, proactive management efforts that have been in place for decades to prevent overfishing in California and the west coast. He should also be aware of the data from Baumgartner that contradicts his faulty conclusions.

D.B. Pleschner is executive director of the California Wetfish Producers Association, a nonprofit dedicated to research and to promote sustainable Wetfish resources.

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