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Atlantic Menhaden: Scientist Sign-On Letter

Atlantic States Marine Fisheries Commission
1050 N. Highland Street, Suite 200 A-N
Arlington, VA 22201

 

Dear Commissioners of the Atlantic States Marine Fisheries Commission’s Menhaden Management Board,

The undersigned 117 scientists write to you about Atlantic menhaden. We hail from a wide variety of areas of expertise, including fisheries ecology, quantitative fisheries biology, marine mammal and bird ecology, and others. We applaud your hard-fought efforts to improve how this key Atlantic forage species is managed coastwide through Amendment 3.[i] We acknowledge that: 1) multiple competing stakeholder interests are at play, 2) there is an ongoing endeavor to generate menhaden-specific ecological reference points (ERPs), and 3) the debate over how to manage menhaden in a way that prioritizes their forage role has continued for over a decade. Nonetheless, we note that there are straightforward and widely accepted options available to you now. Specifically, we urge you to adopt either interim ERP Option C (Pikitch et al.) or Option E (75% target, 40% threshold), and manage with the goal of achieving the corresponding targets, while the Biological/Ecological Reference Points (BERP) workgroup continues to develop menhaden-specific ERPs. Options C and E were derived based on formally peer-reviewed and published ecosystem models that included numerous predator groups and examined broad ecosystem dynamics.

THE SCIENCE IS UNEQUIVOCAL: FORAGE SPECIES MUST BE TREATED MORE CAREFULLY.

There is broad and ever-growing recognition[ii] that forage species are the primary energy conduits between the bottom and top of many marine food webs, and must therefore be managed in a way that protects ecosystem function. These conclusions have been reached using multiple lines of evidence that includes field research, models, and analysis of existing data; they rely upon fundamental ecological principles. It is well-documented that predators have lower survival and reproductive rates when forage populations decline, and in many cases, predator population sizes have been linked to forage populations. As a result, top fisheries scientists, ecologists, and others recommend that decision makers should be cautious when managing key prey, especially in light of changing ocean conditions.

There is strong evidence that points to the critical role that menhaden play as food for numerous predators including important recreational and commercial species like striped bass, tunas, bluefish, sharks, as well as marine mammals and seabirds. Importantly, populations of these predators have been shown to respond negatively to increased fishing pressure on menhaden. Recently, Buchheister et al. (2017), used a northwest Atlantic ecosystem model to show that “…birds, highly migratory species, sharks, and marine mammals were … negatively affected by increased fishing on menhaden,” though none so much as the highly dependent striped bass.[iii] Given these and other findings, including some of our own peer-reviewed work, we emphasize that menhaden abundance significantly impacts predator population abundance. Consequently, we stress that reference points are the crux of Amendment 3.

THE STATUS QUO IS SIMPLY NOT ACCEPTABLE. IT IS INCONSISTENT WITH YOUR OBLIGATIONS.

Reference point Options A (keep single-species reference points and discontinue multi-species modeling work) and B (use single-species reference points until multi-species model and menhaden-specific candidate ERPs are ready in 2020 or later) are unacceptable choices. They would violate the ASMFC Charter to use the best scientific information available.[iv] Options A and B would also result in additional years of the fishery being managed using single-species guidelines that could be used to enact substantial increases over current catch levels while ignoring likely negative impacts on predators, and possibly in reversal and loss of the recently accrued menhaden population growth.  The Menhaden Management Board should avoid such risks. It would contradict the scientific consensus on how to manage forage species. More to the point, enabling such increased risk would be counter to the spirit of Amendment 3.

For those inclined to support Option B because it seems like a guaranteed path to robust, menhaden-specific ERPs, we note that this choice does not mandate that the Menhaden Management Board adopt ERPs derived from the BERP’s models. The BERP’s models are being designed to meet as many management objectives as possible, though they will still require the Board to make hard decisions about tradeoffs. That is, the BERP models are not a panacea that will generate ERPs and fishing quotas to satisfy everyone’s needs. These models also do not directly account for predation mortality from important but sometimes overlooked menhaden predators whose own recoveries are being facilitated by, and are largely relying on, the menhaden recovery. These include such species as humpback whales, osprey, weakfish, and others. Options C and E, in contrast, were derived based on formally peer-reviewed and published ecosystem models that examined broad ecosystem dynamics and included a large number and wide variety of predator groups.

IN THE ABSENCE OF SPECIES-SPECIFIC MODELS AND ERPS, INTERIM OPTIONS THAT ACCOUNT FOR FORAGE ROLES ARE APPROPRIATE AND ESSENTIAL.

In light of the strong evidence that current management approaches are not designed to take into account the variability in forage fish stocks, their unusual life history characteristics, and the role they play in the ecosystem, there are a variety of default recommendations available for fishery managers to use for situations in which species-specific ERPs are unavailable. These alternatives to single-species approaches are based on a comprehensive accounting of forage fish and their ecosystems, developed over the course of many years for a diverse array of ecosystems. Importantly, these alternatives invariably agree on: 1) the need for reference points that aim to generate higher prey biomasses (targets); 2) higher minimum biomass limits (thresholds) to avoid; 3) and fishing mortality rate maximums that are lower than those used in traditional fisheries management.

In Amendment 3, both reference point Options C and E would achieve these objectives, and once implemented, should help the menhaden population to continue to increase in abundance and biomass. At a time when many of their predator populations are in decline and showing cause for concern, this is not the time to wait for a different solution. Options C and E would not preclude the BERP workgroup from continuing its important work to finalize menhaden-specific multispecies models that can be used to generate ERPs. When available, their findings and recommendations can (and should) be compared to the results of Buchheister et al. (2017) to better understand the performance of reference points.

Option C is a more conservative approach than Option E, and would be highly protective of the role that menhaden play as forage. The inclusion of a harvest control rule in Option C ensures that managers will respond to changes in menhaden biomass in a rapid and predictable way. The fishing prohibition required at biomasses below 40% virgin biomass (B0) and the maximum allowed fishing mortality of one-half of natural mortality (½M) would help to avoid stock statuses that might impact menhaden spawning potential and the diets of predators.

Option E does not prescribe a control rule and thus provides a degree of flexibility for managers, but one that could result in potentially risky decisions at low menhaden biomasses, though it is still more protective of the dietary needs of predators than Options A and B. Option E is structured in a way that is similar to the current biological reference points, with a biomass-based target and threshold and corresponding fishing mortality-based target and threshold. There is insufficient information in draft Amendment 3 to compare the differences in expected outcomes between Options C and E and to assess the management tradeoffs, but the implementation of such ERPs is not novel.

THERE IS PRECEDENT FOR USING ERPs FOR FORAGE FISH

As the scientific consensus converges around the need to manage forage species in a precautionary manner, forward-thinking managers and industries are adopting these recommendations in practice. Early adopters include:

  • The Convention on the Conservation of Antarctic Marine Living Resources (which manages krill in such a way that prioritizes the needs of predators) which was one of the first to adopt a maximum fishing mortality rate of ½ Fmsy and a 75% biomass target;[v]
  • The Monterey Bay Aquarium’s Seafood Watch program[vi] (which adopted assessment criteria embodied in Option C);
  • The Marine Stewardship Council[vii] (which adopted certification criteria similar to Option E, including a 75% biomass target and a high minimum biomass threshold); and,
  • The Pacific, North Pacific, and Mid-Atlantic Councils, as well as several west coast states (which have prohibited the directed, commercial-scale harvest of many forage – or ecosystem component – species).

We urge the Menhaden Management Board to pursue swift implementation of ERPs through Amendment 3 to protect the growing menhaden population and its many predators. This historic step forward would be in keeping with the recommendations of a large and growing body of science, and will serve to set the stage for the eventual release of BERP-derived ERPs.

Thank you for your consideration,

 

Aaron Adams, Ph.D.
Director of Science and Conservation
Bonefish and Tarpon Trust, Coral Gables, FL

Karen Alexander, Ph.D.
Project Manager, New Hampshire Sea Grant
University of New Hampshire, Durham, NH

Barry Allen, Ph.D.
Associate Professor of Environmental Studies
Rollins College, Winter Park, FL

Dennis Allen, Ph.D.
Research Professor and Director
Baruch Marine Field Laboratory
University of South Carolina, Georgetown, SC

Edward Ames M.S.
Retired Professor, Bowdoin College and University of Maine Orono
Penobscot East Resource Center, Stonington, ME

Jerald S. Ault, Ph.D.
Professor and Chair, Department of Marine Ecosystems and Society
Director, Tarpon and Bonefish Research Center
Rosenstiel School of Marine and Atmospheric Science
University of Miami, Miami, FL

Andrew Bakun Ph.D.
Professor, Department of Marine Ecosystems and Society
University of Miami, Miami, FL

Julia Baum, Ph.D.
Associate Professor of Biology
University of Victoria, BC, Canada

Robert Beardsley Ph.D.
Scientist Emeritus
Woods Hole Oceanographic Institute, Woods Hole, MA

Mimi Larsen Becker, Ph.D.
Professor Emeritus, School of Marine and Ocean Engineering
University of New Hampshire, Durham, NH

Jean G. Boal, Ph.D.
Professor, Animal Behavior and Marine Biology
Millersville University, Millersville, PA

P. Dee Boersma Ph.D.
Professor, Dept. of Biology
University of Washington, Seattle, WA

W. Jeffrey Bolster, Ph.D.
Professor of History
University of New Hampshire, Durham, NH

Mark Bond, Ph.D.
Postdoctoral Scientist
Florida International University, Miami, FL

Roelof Boumans, Ph.D.
Director
Accounting FOR Desirable Futures LLC, Charlotte, VT

Barbara Brennessel, Ph.D.
Professor Emerita
Wheaton College, Norton, MA

Alejandro Buren, Ph.D.
Fisheries and Oceans Canada, Ottawa, Canada

Jeb Byers, Ph.D.
Josiah Meigs Professor of Ecology
Odum School of Ecology
University of Georgia, Athens, GA

John Cannon, Ph.D.
Conservation Biologist
Conservation Science Institute, Front Royal, VA

David Conover, Ph.D.
Vice President for Research and Innovation
Professor of Biology
University of Oregon, Eugene, OR

Robert Crawford, Ph.D.
Professor, Oceans and Coasts, Department of Environmental Affairs
University of Cape Town, Cape Town, South Africa

Benjamin Cuker, Ph.D.
Department of Marine and Environmental Science
Hampton University, Hampton, VA

Philippe Cury, Ph.D.
Senior IRD Scientist
Brussels, Belgium

Dominique Didier
Professor of Biology
Millersville University, Millersville, PA

James K. Dooley, Ph.D.
Professor, Biology
Adelphi University, Garden City, NY

David Dow, Ph.D.
NOAA Fisheries, Northeast MA

J. Marcus Drymon, Ph.D.
Assistant Extension Professor, Coastal Research and Extension Center
Mississippi State University, Biloxi, MS

Tara Duffy, Ph.D.
Lecturer, Marine Sciences, Zoology, Evolution and Marine Pollution
Northeastern University, Boston, MA

Karen Eckert, Ph.D.
Professor and Director
Principia College Center for Sustainability, Elsah, IL

Tim Essington, Ph.D.
Professor and Associate Director, School of Aquatic and Fisheries Science
University of Washington, Seattle, WA

James A. Estes, Ph.D.
Professor, Ecology and Evolutionary Biology
University of California Santa Cruz, Santa Cruz, CA

Eileen Fielding, Ph.D.
Executive Director
Farmington River Watershed Association, Simsbury, CT

Adrian Forsythe, Ph.D.
Director, Andes Amazon Fund
President, Board of the Amazon Conservation Association
Blue Moon Fund, Charlottesville, VA

Carol Foss, Ph.D.
New Hampshire Audubon, NH

Anamarija Frankic, Ph.D.
Director, Green Harbors Project and Biomimicry LivingLabs
Co-Founder, Biomimicry New England
Boston, MA

Aaren Freeman, Ph.D.
Associate Professor, Biology Department
Adelphi University, Garden City, NY

Allen Friedlander, Ph.D.
Chief Scientist, Pristine Seas, National Geographic Society
Fisheries Ecology and Research Lab
Department of Biology
University of Hawaii, Honolulu, HI

Austin Gallagher, Ph.D.
Founder and CEO, Beneath the Waves
Beneath the Waves, Miami, FL

Joseph Garcia, Ph.D.
Professor, Geography, Earth Science
Earth Science Program Coordinator
Longwood University, Farmville, VA

Grant Gilmore, Ph.D.
Senior Scientist
Estuarine, Coastal and Ocean Science Inc., Vero Beach, FL

Ralf Goericke, Ph.D.
Researcher, Integrative Oceanography
University of California, San Diego
Scripps Institute of Oceanography, San Diego, CA

Suchi Gopal, Ph.D.
Professor, Department of Earth and Environment, Center for Remote Sensing
Pardee Center Faculty Research Fellow
Boston University, Boston, MA

Natasha Gownaris, Ph.D.
Research Associate, Department of Biology
University of Washington, Seattle, WA

Susan Gresnens, Ph.D.
Professor, Department of Biological Sciences
Towson University, Towson, MD

Gary Grossman, Ph.D.
Professor, Animal Ecology
University of Georgia, Athens, GA

Eric Hallerman, Ph.D.
Fellow, American Fisheries Society
Department of Fish and Wildlife Conservation
Virginia Polytechnic Institute, Blacksburg, VA

Neil Hammerschlag, Ph.D.
Research Assistant Professor, Rosenstiel Marine School, Abess Center, Predator Ecology Lab, Shark
Research and Conservation Program
University of Miami, Miami, FL

Jeremy Jackson, Ph.D.
Staff Scientist Emeritus, Marine Ecology, Paleobiology, Conservation Science
Smithsonian Tropical Research Institute
University of California San Diego, San Diego, CA

William Johnson, Ph.D.
Professor Emeritus
Biological Sciences
Goucher College, Towson, MD

Zack Jud, Ph.D.
Director of Education and Exhibits
Florida Oceanographic Society, Stuart, FL

Peter Jumars, Ph.D.
Professor Emeritus of Marine Sciences, University of Maine
Twisp, WA

Les Kaufman, Ph.D.
Professor of Biology
Boston University, Boston, MA

David Kerstetter, Ph.D.
Assistant Professor
Halmos College of Natural Sciences and Oceanography
Nova Southeastern University, Dania Beach, FL

Emily Klein, Ph.D.
Postdoctoral Fellow
Antarctic Ecosystem Research Division
The Farallon Institute, CA

Thomas Klinger, Ph.D.
Professor of Biology
Graduate Coordinator
Advisor for Natural History and Marine Biology, Department of Biological and Allied Health Sciences
Bloomsburg University, Bloomsburg, PA

Stephen W. Kress, Ph.D.
Executive Director, Audubon Project Puffin
National Audubon Society, NY

William Leavenworth, Ph.D.
Retired Senior Research Fellow at Environmental Conservation, University of Massachusetts Amherst
Bangor, ME

Dana Lepofsky, Ph.D.
Professor, Department of Archaeology
Simon Fraser University, BC, Canada

Phillip Levin, Ph.D.
Professor, School of Environmental & Forest Sciences
University of Washington, Seattle, WA

Ken Lindeman, Ph.D.
Professor, Education and Interdisciplinary Studies
Florida Institute of Technology, Melbourne, FL

Darcy Lonsdale, Ph.D.
Professor, School of Marine and Atmospheric Sciences
Stony Brook University, Stony Brook, NY

Thomas Lovejoy, Ph.D.
Professor, Department of Environmental Science and Policy
George Mason University, Fairfax, VA

Alec McCall, Ph.D.
Member, Farallon Institute Board of Directors
Farallon Institute, Petaluma, CA

Marc Mangel, Ph.D.
Distinguished Research Professor of Mathematical Biology
University of California Santa Cruz, Santa Cruz, CA

Kathryn Matthews, Ph.D.
Deputy Chief Scientist
Oceana, Washington, D.C.

Loren McClenachan, Ph.D.
Elizabeth and Lee Ainslie Assistant Professor of Environmental Studies at Colby College
Colby College, Waterville, ME

Matthew McKenzie, Ph.D.
Associate Professor of History
University of Connecticut, Storrs, CT

Aaron McNevin, Ph.D.
Director of Aquaculture
World Wildlife Fund, Washington, D.C.

Rob Moir, Ph.D.
President and Executive Director
Ocean River Institute, Cambridge, MA

William A. Montevecchi, Ph.D.
University Research Professor of Psychology, Biology, Ocean Sciences
Memorial University of Newfoundland, St. John’s, Canada

Stephen Munch, Ph.D.
Associate Adjunct Professor, Research Associate, Physical and Biological Sciences
University of California Santa Cruz, Santa Cruz, CA

Rosamund L. Naylor, Ph.D.
Gloria and Richard Kushel Director of the Center on Food Security and the Environment
Stanford University, Stanford, CA

Emily Nodine, Ph.D.
Assistant Professor of Environmental Studies
Rollins College, Winter Park, FL

Janet Nye, Ph.D.
Assistant Professor, School of Marine and Atmospheric Science
Stony Brook University, Stony Brook, NY

Michael K. Orbach, Ph.D.
Professor of the Practice Emeritus of Marine Affairs and Policy
Nicholas School of the Environment, Duke University, Beaufort NC

Donald Orth, Ph.D.
Thomas H. Jones Professor, College of Natural Resources and Environment
Virginia Tech University, Blacksburg, VA

Maria Lourdes Palomares, Ph.D.
Senior Scientist, Sea Around Us Project
University of British Columbia, BC, Canada

Daniel Pauly, Ph.D.
Killam Professor, Sea Around Us, Institute for the Oceans and Fisheries and Department of Zoology
University of British Columbia, BC, Canada

Ernst Peebles, Ph.D.
Associate Professor
College of Marine Science
University of South Florida, St. Petersburg, FL

Esther Peters, Ph.D.
Associate Professor, Environmental Science and Policy
George Mason University, Fairfax, VA

Ellen Pikitch, Ph.D.
Professor and Executive Director, Institute for Ocean Conservation Science
School of Marine and Atmospheric Science
Stony Brook University, Stony Brook, NY

Leslie Poole, Ph.D.
Assistant Professor of Environmental Studies
Rollins College, Winter Park, FL

Andrew Read, Ph.D.
Stephen A. Toth Professor of Marine Biology
Director, Duke Marine Lab
Duke University, Beaufort, NC

Jennifer Rehange, Ph.D.
Associate Professor
Earth and Environmental Research Center
Florida International University, Miami, FL

Aaron Rice, Ph.D.
Bioacoustics Research Program
Cornell Laboratory of Ornithology
Cornell University, Ithaca, NY

Callum Roberts, Ph.D.
Professor of Marine Conservation
Environment Department
University of York, York, U.K.

Joe Roman, Ph.D.
Gund Institute for Environment
Rubenstein School of Environment and Natural Resources
University of Vermont, Burlington, VT

Steve Ross, Ph.D.
Research Professor
Center for Marine Sciences
University of North Carolina Wilmington, Wilmington, NC

Carl Safina, Ph.D.
Endowed Professor, School of Marine and Atmospheric Science
Stony Brook University, Stony Brook, NY

James Salierno, Ph.D.
Associate Professor of Biology, Chair Department of Biological Sciences
Fairleigh Dickinson University, Madison, NJ

Anne Saloman, Ph.D.
Associate Professor
Coastal Marine Ecology and Conservation Lab, School of Resource and Environmental Management
Simon Fraser University, BC, Canada

Gorka Sancho, Ph.D.
Professor, Department of Biology
College of Charleston, Charleston, SC

Eric Schultz, Ph.D.
Associate Professor, Department of Ecology and Evolutionary Biology
University of Connecticut, Storr, CT

Johnathan Shenker, Ph.D.
Associate Professor of Biological Sciences
Florida Institute of Technology, Melbourne, FL

David Shiffman, Ph.D.
Marine Conservation Biologist and Science Writer, Liber Ero Postdoctoral Research Fellow
Simon Fraser University, BC, Canada

Mahmood Shivji, Ph.D.
Director, Guy Harvey Research Institute
Director, Save Our Seas Shark Research Center
Nova Southeastern University, Fort Lauderdale, FL

Miles Silman, Ph.D.
Andrew Sabin Family Foundation Professor of Conservation Biology
Director, Center for Energy, Environment and Sustainability
Wake Forest University, Winston-Salem, NC

David L. Smith, Ph.D.
Professor of Biological Sciences
Smith College, Northampton, MA

Paul Spitzer, Ph.D.
Trappe, MD

Ben Steele, Ph.D.
Professor and M. Roy London Endowed Chair, Department of Natural Sciences
Colby-Sawyer College, New London, NH

Robert Steneck, Ph.D.
Professor of Oceanography, Marine Biology and Marine Policy, School of Marine Sciences
Pew Fellow in Marine Conservation
University of Maine, Walpole, ME

Robert Stevenson, Ph.D.
Department of Biology
University of Massachusetts, Boston, MA

William Sydeman, Ph.D.
President, Farallon Institute
Farallon Institute, Petaluma, CA

Alina M. Szmant, Ph.D.
Adjunct Professor of Marine Science
Center for Marine Science
University of North Carolina, Wilmington, NC

John Terborgh, Ph.D.
James B. Duke Professor of Environmental Science
Co-Director, Center for Tropical Conservation
Duke University, Durham, NC

Julia Thayer, Ph.D.
Scientist at Farallon Institute for Advanced Ecosystem Research
Farallon Institute, Petaluma, CA

Simon Thorrold, Ph.D.
Biology Department MS #50
Woods Hole Oceanographic Institution, Woods Hole, MA

Shea Tuberty, Ph.D.
Professor, Invertebrate Physiology and Aquatic Ecotoxicology
Appalachian State University, Boone, NC

Eugene R. Turner, Ph.D.
Department of Oceanography and Coastal Sciences, College of the Coast and Environment
Louisiana State University, Baton Rouge, LA

Megan Tyrrell Ph.D.
Research Coordinator
Waquoit Bay National Estuarine Research Reserve, Waquoit, MA

Ivan Valiela, Ph.D.
Distinguished Scientist, The Ecosystems Center
Marine Biological Laboratory, Woods Hole, MA

Charles Walcott, Ph.D.
Professor Emeritus
Cornell University, Ithaca, NY

John Waldman, Ph.D.
Professor of Biology, Queens College
City University of NY, NY

Joseph Warren, Ph.D.
Associate Professor
School of Marine and Atmospheric Sciences
Stony Brook University, Stony Brook, NY

Judith Weis, Ph.D.
Professor Emerita, Department of Biological Sciences
Rutgers University, Newark, NJ

Crow White, Ph.D.
Assistant Professor of Biology
California Polytechnic State University, San Luis Obispo, CA

Peter Wimberger, Ph.D.
Professor of Biology
University of Puget Sound, Tacoma, WA

Kirk Winemiller, Ph.D.
Department of Wildlife and Fisheries Sciences and Program of Ecology and Evolutionary Biology
Texas A&M University, College Station, TX

 

Signees Scientists Support (PDF) 

 

[i] ASMFC (2017). Draft Amendment 3 to the Interstate Fishery Management Plan for Atlantic Menhaden For Public Comment.

[ii] For example, see: Cury, P.M. et al. (Dec. 2011). Global Seabird Response to Forage Fish Depletion—One-Third for the Birds. Science: 334(6063), p. 1703-1706; Essington, T.E. et al. (2015). Fishing amplifies forage fish population collapses. Proc. Natl. Acad. Sci.: 112(21), p. 6648-6652; Pikitch, E. et al. (2012). Little Fish, Big Impact: Managing a Crucial Link in Ocean Food Webs. Lenfest Ocean Program, Wash., DC; Pikitch, E. et al. (2017). The strong connection between forage fish and their predators: A response to Hilborn et al. (2017). Fisheries Research; J.P. Roux, J.P et al. (2013). Jellyfication of marine ecosystems as a likely consequence of overfishing small pelagic fishes: lessons from the Benguela. Bull. Mar. Sci.: 89(1), p. 249-284; Smith, A.D.M. et al. (July 2011). Impacts of Fishing Low-Trophic Level Species on Marine Ecosystems. Science: 333(6046), p. 1147-1150.

[iii] Buchheister, A, Miller, T.J., & E.D. Houde (2017). Evaluating ecosystem-based reference points for Atlantic menhaden (Brevoortia tyrannus). Marine and Coastal Fisheries, DOI: 10.1080/19425120.2017.1360420

[iv] ASMFC (Feb. 2016). Interstate Fisheries Management Program Charter.

[v] Gascón, V. & R. Werner (2006). CCAMLR and Antarctic Krill: Ecosystem Management Around the Great White Continent. Sustainable Development Law & Policy: 7(1): p. 14-16.

[vi] Monterey Bay Aquarium (Dec. 2016). Seafood Watch Standard for Fisheries Version F3.2.

[vii] Marine Stewardship Council (Oct. 2014). Fisheries Certification Requirements and Guidance, Version 2.0.

Greetings.

On behalf of Dr.’s Marc Mangel, Tim Essington, Dee Boersma, Les Kaufman, Bill Sydeman, and myself, we request your help to advance fisheries management of a key forage fish, Atlantic menhaden. Menhaden are a major prey item in the diets of many beloved and economically important predators including striped bass, bluefish, tunas, weakfish, cod, king mackerel, cobia, osprey, and humpback whales. The body that manages menhaden – the Atlantic States Marine Fisheries Commission – is on the verge of an historic action that would transition management from a single-species approach (i.e., one that is solely focused on menhaden stock dynamics and the needs of its fishery) to an ecosystem one that prioritizes its role as prey.

To do this, we need your help. The Commission relies on input from the public, industry, and especially scientists like you. Please take a moment to read the attached letter that advocates for the Commission to immediately transition to the use of ecological reference points. These “guideposts” will help managers and the public alike to interpret stock status and set catch limits in a way that is protective of the role menhaden play as forage. Many of you have already contributed significantly to this important body of work; we are presented here with a rare opportunity to see those efforts culminate in on-the-water change.

The Commission is accepting public comments on this action until October 20, with final action set for November 13th. Already, thousands of members of the public have weighed in. We hope that you will agree to help encourage the Commission to make this potentially historic change, and encourage you to reach out to your colleagues to further build the drumbeat for ecosystem-based fisheries management by co-signing the letter.

Thank you,

Dr.’s Ellen Pikitch, Marc Mangel, Tim Essington, Dee Boersma, Les Kaufman, Bill Sydeman and Barbara Brennessel

Atlantic States Marine Fisheries Commission
1050 N. Highland Street, Suite 200 A-N
Arlington, VA 22201

Dear Commissioners of the Atlantic States Marine Fisheries Commission’s Menhaden Management Board,

The undersigned XX scientists write to you about Atlantic menhaden. We hail from a wide variety of areas of expertise, including fisheries ecology, quantitative fisheries biology, marine mammal and bird ecology, and others. We applaud your hard-fought efforts to improve how this key Atlantic forage species is managed coastwide through Amendment 3.[i] We acknowledge that: 1) multiple competing stakeholder interests are at play, 2) there is an ongoing endeavor to generate menhaden-specific ecological reference points (ERPs), and 3) the debate over how to manage menhaden in a way that prioritizes their forage role has continued for over a decade. Nonetheless, we note that there are straightforward and widely accepted options available to you now. Specifically, we urge you to adopt either interim ERP Option C (Pikitch et al.) or Option E (75% target, 40% threshold), and manage with the goal of achieving the corresponding targets, while the Biological/Ecological Reference Points (BERP) workgroup continues to develop menhaden-specific ERPs. Options C and E were derived based on formally peer-reviewed and published ecosystem models that included numerous predator groups and examined broad ecosystem dynamics.

THE SCIENCE IS UNEQUIVOCAL: FORAGE SPECIES MUST BE TREATED MORE CAREFULLY.

There is broad and ever-growing recognition[ii] that forage species are the primary energy conduits between the bottom and top of many marine food webs, and must therefore be managed in a way that protects ecosystem function. These conclusions have been reached using multiple lines of evidence that includes field research, models, and analysis of existing data; they rely upon fundamental ecological principles. It is well-documented that predators have lower survival and reproductive rates when forage populations decline, and in many cases, predator population sizes have been linked to forage populations. As a result, top fisheries scientists, ecologists, and others recommend that decision makers should be cautious when managing key prey, especially in light of changing ocean conditions.

There is strong evidence that points to the critical role that menhaden play as food for numerous predators including important recreational and commercial species like striped bass, tunas, bluefish, sharks, as well as marine mammals and seabirds. Importantly, populations of these predators have been shown to respond negatively to increased fishing pressure on menhaden. Recently, Buchheister et al. (2017), used a northwest Atlantic ecosystem model to show that “…birds, highly migratory species, sharks, and marine mammals were … negatively affected by increased fishing on menhaden,” though none so much as the highly dependent striped bass.[iii] Given these and other findings, including some of our own peer-reviewed work, we emphasize that menhaden abundance significantly impacts predator population abundance. Consequently, we stress that reference points are the crux of Amendment 3.

THE STATUS QUO IS SIMPLY NOT ACCEPTABLE. IT IS INCONSISTENT WITH YOUR OBLIGATIONS.

Reference point Options A (keep single-species reference points and discontinue multi-species modeling work) and B (use single-species reference points until multi-species model and menhaden-specific candidate ERPs are ready in 2020 or later) are unacceptable choices. They would violate the ASMFC Charter to use the best scientific information available.[iv] Options A and B would also result in additional years of the fishery being managed using single-species guidelines that could be used to enact substantial increases over current catch levels while ignoring likely negative impacts on predators, and possibly in reversal and loss of the recently accrued menhaden population growth.  The Menhaden Management Board should avoid such risks. It would contradict the scientific consensus on how to manage forage species. More to the point, enabling such increased risk would be counter to the spirit of Amendment 3.

For those inclined to support Option B because it seems like a guaranteed path to robust, menhaden-specific ERPs, we note that this choice does not mandate that the Menhaden Management Board adopt ERPs derived from the BERP’s models. The BERP’s models are being designed to meet as many management objectives as possible, though they will still require the Board to make hard decisions about tradeoffs. That is, the BERP models are not a panacea that will generate ERPs and fishing quotas to satisfy everyone’s needs. These models also do not directly account for predation mortality from important but sometimes overlooked menhaden predators whose own recoveries are being facilitated by, and are largely relying on, the menhaden recovery. These include such species as humpback whales, osprey, weakfish, and others. Options C and E, in contrast, were derived based on formally peer-reviewed and published ecosystem models that examined broad ecosystem dynamics and included a large number and wide variety of predator groups.

IN THE ABSENCE OF SPECIES-SPECIFIC MODELS AND ERPS, INTERIM OPTIONS THAT ACCOUNT FOR FORAGE ROLES ARE APPROPRIATE AND ESSENTIAL.

In light of the strong evidence that current management approaches are not designed to take into account the variability in forage fish stocks, their unusual life history characteristics, and the role they play in the ecosystem, there are a variety of default recommendations available for fishery managers to use for situations in which species-specific ERPs are unavailable. These alternatives to single-species approaches are based on a comprehensive accounting of forage fish and their ecosystems, developed over the course of many years for a diverse array of ecosystems. Importantly, these alternatives invariably agree on: 1) the need for reference points that aim to generate higher prey biomasses (targets); 2) higher minimum biomass limits (thresholds) to avoid; 3) and fishing mortality rate maximums that are lower than those used in traditional fisheries management.

In Amendment 3, both reference point Options C and E would achieve these objectives, and once implemented, should help the menhaden population to continue to increase in abundance and biomass. At a time when many of their predator populations are in decline and showing cause for concern, this is not the time to wait for a different solution. Options C and E would not preclude the BERP workgroup from continuing its important work to finalize menhaden-specific multispecies models that can be used to generate ERPs. When available, their findings and recommendations can (and should) be compared to the results of Buchheister et al. (2017) to better understand the performance of reference points.

Option C is a more conservative approach than Option E, and would be highly protective of the role that menhaden play as forage. The inclusion of a harvest control rule in Option C ensures that managers will respond to changes in menhaden biomass in a rapid and predictable way. The fishing prohibition required at biomasses below 40% virgin biomass (B0) and the maximum allowed fishing mortality of one-half of natural mortality (½M) would help to avoid stock statuses that might impact menhaden spawning potential and the diets of predators.

Option E does not prescribe a control rule and thus provides a degree of flexibility for managers, but one that could result in potentially risky decisions at low menhaden biomasses, though it is still more protective of the dietary needs of predators than Options A and B. Option E is structured in a way that is similar to the current biological reference points, with a biomass-based target and threshold and corresponding fishing mortality-based target and threshold. There is insufficient information in draft Amendment 3 to compare the differences in expected outcomes between Options C and E and to assess the management tradeoffs, but the implementation of such ERPs is not novel.

THERE IS PRECEDENT FOR USING ERPs FOR FORAGE FISH

As the scientific consensus converges around the need to manage forage species in a precautionary manner, forward-thinking managers and industries are adopting these recommendations in practice. Early adopters include:

  • The Convention on the Conservation of Antarctic Marine Living Resources (which manages krill in such a way that prioritizes the needs of predators) which was one of the first to adopt a maximum fishing mortality rate of ½ Fmsy and a 75% biomass target;[v]
  • The Monterey Bay Aquarium’s Seafood Watch program[vi] (which adopted assessment criteria embodied in Option C);
  • The Marine Stewardship Council[vii] (which adopted certification criteria similar to Option E, including a 75% biomass target and a high minimum biomass threshold); and,
  • The Pacific, North Pacific, and Mid-Atlantic Councils, as well as several west coast states (which have prohibited the directed, commercial-scale harvest of many forage – or ecosystem component – species).

We urge the Menhaden Management Board to pursue swift implementation of ERPs through Amendment 3 to protect the growing menhaden population and its many predators. This historic step forward would be in keeping with the recommendations of a large and growing body of science, and will serve to set the stage for the eventual release of BERP-derived ERPs.

Thank you for your consideration,

[i] ASMFC (2017). Draft Amendment 3 to the Interstate Fishery Management Plan for Atlantic Menhaden For Public Comment.

[ii] For example, see: Cury, P.M. et al. (Dec. 2011). Global Seabird Response to Forage Fish Depletion—One-Third for the Birds. Science: 334(6063), p. 1703-1706; Essington, T.E. et al. (2015). Fishing amplifies forage fish population collapses. Proc. Natl. Acad. Sci.: 112(21), p. 6648-6652; Pikitch, E. et al. (2012). Little Fish, Big Impact: Managing a Crucial Link in Ocean Food Webs. Lenfest Ocean Program, Wash., DC; Pikitch, E. et al. (2017). The strong connection between forage fish and their predators: A response to Hilborn et al. (2017). Fisheries Research; J.P. Roux, J.P et al. (2013). Jellyfication of marine ecosystems as a likely consequence of overfishing small pelagic fishes: lessons from the Benguela. Bull. Mar. Sci.: 89(1), p. 249-284; Smith, A.D.M. et al. (July 2011). Impacts of Fishing Low-Trophic Level Species on Marine Ecosystems. Science: 333(6046), p. 1147-1150.

[iii] Buchheister, A, Miller, T.J., & E.D. Houde (2017). Evaluating ecosystem-based reference points for Atlantic menhaden (Brevoortia tyrannus). Marine and Coastal Fisheries, DOI: 10.1080/19425120.2017.1360420

[iv] ASMFC (Feb. 2016). Interstate Fisheries Management Program Charter.

[v] Gascón, V. & R. Werner (2006). CCAMLR and Antarctic Krill: Ecosystem Management Around the Great White Continent. Sustainable Development Law & Policy: 7(1): p. 14-16.

[vi] Monterey Bay Aquarium (Dec. 2016). Seafood Watch Standard for Fisheries Version F3.2.

[vii] Marine Stewardship Council (Oct. 2014). Fisheries Certification Requirements and Guidance, Version 2.0.

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