Many groups in the environmental community have come out in opposition to the Fishery Science Improvement Act (H.R. 2304). While some of those groups have reacted in typical knee-jerk fashion, labeling supporters of the bill as favoring “extinction,” the more thoughtful among them have circulated concerns that are no less illogical, but perhaps more diplomatically phrased.
Opponents of FSIA disapprove of the bill’s requirement that managers have a modern, recent assessment in hand in order to set an annual catch limit (ACL) for a stock of fish. Terrestrial and freshwater wildlife resource management agencies would not think of operating without standardized stock surveys and assessments. Yet, for our marine resources, it appears that some groups believe that “readily available information such as biology” is adequate to replace a standardized, peer-reviewed stock assessment as the foundation of management, even when it has drastic social and economic consequences. A hodgepodge of partial bits of information that perhaps add up to an informed guess will always fall short of the standards we as a nation have used for managing our fish and wildlife resources.
At its core, FSIA rejects the notion that a swag — a scientific wild ass guess — is good enough to be the foundation of management for hundreds of marine stocks that have either never had an assessment or have been deemed inadequately assessed by NOAA Fisheries.
From their same artful hatchet job opponents maintain: FSIA would “undermine the ACL requirement by exempting managers from setting science-based catch limits for fish populations that have not been assessed in the past five years. It would also prevent managers from using scientifically valid methods for establishing catch limits based on existing and readily available information such as the biology of the species and recent commercial and recreational catch data.”
In fact, federal fisheries managers have taken actions in the past to prevent overfishing in the absence of a quantitative assessment by proactive use of aggregate bag limits, vessel limits, minimum size limits, gear restrictions, seasonal and areal closures and other common sense measures. Without passage of H.R. 2304, managers will be forced to abandon these approaches and set an artificial quota (a dart thrown at the wall) in pounds per year without the science to back such measures. In response to this conundrum, the regional fishery management councils currently are removing species from management plans and leaving them without any conservation measures for protection. You will not see that harsh reality addressed in any of the attack pieces currently circulating.
The inaccurate ENGO piece also distorts the status quo and misleads the reader on the legislation when it claims, “The misnamed ‘Fisheries Science Improvement Act’ would create a new loophole that could allow the Secretary of Commerce to exempt scores of fish species from the requirement to establish science-based catch limits, including those that are undergoing overfishing. H.R. 2304 would establish a new, ill-defined category of fish populations known as ‘ecosystem stocks’ that are exempt from catch limits.”
In fact, ecosystem management has been promoted by scientists and conservationists for years and is currently used by NOAA Fisheries. But to manage larger core groups of like-species as “ecosystem stocks” with aggregate bag limits, vessel limits, minimum size limits, gear restrictions, seasonal and areal closures and other common sense measures will provide broad protections for the greatest number of species while science catches up with specific quantitative assessments.
The stocks we know are vulnerable (through assessments) are already being managed by catch limits and other conservation tools. We do not know the status of the vast majority of other species now covered by federal fishery management plans. H.R. 2304 will promote the development of the data and science necessary to determine the status of these data-poor stocks while allowing the fishery management councils to continue managing them with measures other than arbitrary caps on annual pounds landed. This will let the councils retain the ability to use existing tools, their backgrounds and experience, and common sense to forge a balanced management approach that provides protection to these stocks without unnecessarily crushing the economic engine provided to this country by the businesses that support the fishing industry.
The specious claim advanced is that the mere existence of the statutory ACL requirement has improved stock assessments and data collection. Nothing could be further from the truth. Not a single ACL has been implemented for any of the hundreds of healthy stocks as a result of this provision.
The ENGO then lists stocks of fish that could be exempted from the ACL provisions of the statute as a result of FSIA. I can report that almost without exception, every stock listed is currently managed by quotas, gear restrictions, trip limits, effort limitation programs, closed areas, closed seasons, size limits, and individual and/or aggregate bag limits. All these classic fishery management tools are working.
Let’s not abandon classic fishery management tools for one-size-fits-all ACLs when we do not have the data to inform that decision making. Let’s give improved science a chance to work for conservation.