September 17, 2020 — BUELLTON, Calif. — The following was written by D.B. Pleschner, executive director of the California Wetfish Producers Association:

Thousands of fishermen, processors and allied fishing businesses along the west coast thank the Pacific Fishery Management Council for taking final action on a rebuilding plan for the “northern” stock of Pacific sardine that achieves the balance between conservation and fishing communities mandated by the Magnuson Stevens Fishery Conservation and Management Act (MSA).

This action was required by the MSA after the “northern” sardine stock was declared “overfished” in 2019, when the biomass estimate fell below 50,000 mt. The Council decision came after many months of hard work by stock assessment scientists, modelers, the Coastal Pelagic Species (CPS) Management Team and the Council’s Science and Statistical Committee (SSC), to build and analyze a Rebuilder model based on the 2020 “northern” sardine stock assessment, which covered a period of low recruitment. The herculean effort attempted to forecast future sardine population growth and rebuilding time scenarios under various harvest alternatives.

“The Council’s unanimous decision to support the Management Team’s recommendations shows that they understand reality, the big picture,” said Diane Pleschner-Steele, Executive Director of the California Wetfish Producers Association, representing California fishermen and processors. “Our sardine harvest policy already has a built-in rebuilding plan. The Council closed the main directed fishery in 2015, and sharply reduced incidental harvest rates last year. Further cuts would drive many fishing businesses out of business, and we appreciate the Council’s acknowledgement of that prospect.”

The environmental group Oceana immediately issued a press release decrying the Council action, accusing fishery managers of irresponsible mismanagement. Oceana and other environmental activists based their arguments on the Rebuilder model that scientists, the Management Team and the Council all acknowledged did not reflect reality because it could not model the environmental cycles driving sardine productivity, nor could it predict the future. Further, it assumed that the total harvest allowance was caught every year.

Oceana’s accusation, “fishery managers have failed to learn from the mistakes of history,” does not pass the straight face test when all the facts are presented. During the great sardine decline in the late 1940s, the historic sardine fishery harvested 50 percent or more of the standing stock. Today’s sardine fishery harvest amounts to only 0.6 percent of the northern sardine population — very close to 0 US harvest, which was modeled as Alternative 2, and showed disastrous economic impacts to fishing communities in California and the West Coast because it curtailed major fisheries. Commercial fisheries that take sardines incidentally include market squid, anchovy and mackerel in California and Pacific whiting, pink shrimp and groundfish along the entire West Coast. In addition, the live bait fishery relies on sardines and serves a billion-dollar recreational fishing enterprise.

The Council decision illuminates a dicey problem: sardine fishery management policy assumes that two sardine stocks exist along the west coast and Mexico, divided by a temperature barrier at about 62 degrees F. But the Council manages only the “northern” stock, and in recent years, stock assessments have subtracted thousands of tons of sardines found in waters warmer than 62 degrees on the assumption that those were “southern” sardines that migrated up from Mexico. Stock assessments also are now based on annual NOAA summer acoustic trawl (AT) surveys that begin in the Pacific Northwest and move south, not reaching California waters until late August, when water temperatures are typically above 62 degrees. Thus, most California sardines are now omitted from “northern” stock assessments on the assumption they are “southern” sardines. Also, NOAA research ships are too large to survey near shore, where most fishing occurs in California. For the past few years, fishermen have testified to a growing abundance of sardines on their fishing grounds yearlong. But complicating matters even further, for management purposes, all sardines landed are subtracted from the “northern” sardine harvest allowance, regardless of sea temperature. This catch-22 sets the backstory for the Council’s final decision.

Due to Covid-19 restrictions the Council meeting was conducted via webinar, and parade of fishermen, seafood processors and community representatives testified to the hardship they are already experiencing under current restrictions. They all voiced unanimous support for Alternative 1, “status quo” fishing regulations. The Management Team also recommended Alternative 1 as the most balanced and flexible choice. Environmental groups testified as well, and all supported Alternative 3, a static five percent harvest rate hard-wired for close to 20 years, based on Rebuilder model analysis, that would have cut current harvest levels nearly in half, precipitating harsh economic impacts.

In their deliberations, Council members highlighted the flexibility of the “status quo” sardine Harvest Control Rule (HCR) that sets harvest limits based on current environmental conditions. They concurred with scientists and the Management Team that the Rebuilder model does not reflect reality; it can’t model the natural high and low productivity cycles of sardines. Council members recognized that the HCR’s precautionary harvest limits are designed to provide forage for predators. Respecting both the need for conservation and the needs of fishing communities, Washington Councilmember Phil Anderson commented that he would rather provide a little more harvest now to keep fishing communities viable. Otherwise they might not survive into the future. Council chair Marc Gorelnik summarized discussion with his comment, “Mother Nature bats last.”

Scientists and Council members alike recognize that environmental conditions are key to stock rebuilding, as they have been for eons even without fishing. The Management Team pointed out that actual fishery catches in the past five years, since the main directed fishery was closed, have averaged only about 2,300 metric tons, far short of the allowed annual catch target, and most of the catch is “southern” stock sardines. The Council also recognized that the current HCR equates to a built-in rebuilding plan because it has flexibility to reduce catches in relation to the biomass, and also includes automatic actions to further restrict fishing in low abundance years. The Council has already reduced the fishery as far as feasibly possible. Now Mother Nature needs to do the rest.

All things considered, the Council made the proper rebuilding plan decision, following the MSA mandates to specify a time period for rebuilding that is as short as possible, taking into account the biology of the stock and needs of fishing communities. The MSA does allow directed fishing to continue when rebuilding an overfished stock, and does not require instant recovery or the most drastic action be taken. Optimum Yield is a long-term goal. The MSA also allows flexibility in developing a rebuilding plan. The plan will be updated when new information is available – nothing is cast in stone.

In light of evidence of recruitment and the abundance of sardines that California fishermen have been reporting inshore of AT surveys, fishery representatives are asking for a review of the rebuilding plan in 2021 as soon as possible after the next coastwide sardine survey, which was cancelled in 2020 due to Covid-19 restrictions, and will for the first time in 2021 include a survey of nearshore waters, in a collaborative effort using fishing industry vessels. The fishing industry is dedicated to help improve the science underpinning stock assessments. “If stock assessments were accurate,” said Corbin Hanson, a highline fisherman who has fished sardines as well as other CPS for more than a decade, “sardines would not be declared ‘overfished.’”