The government is hearing comments ranging all the way from don’t allow hydraulic fracturing at all on federal lands, to don’t pass new rules regulating it on such lands, as it considers a proposal to do the latter.
A public comment period ended Friday on a Bureau of Land Management proposal to update drilling rules on federal lands to reflect the widespread use of modern fracking techniques in oil and gas development.
Food & Water Watch estimates that more than 1 million comments have been submitted to the White House and BLM “urging them to protect public lands from fracking.” It said a coalition of 276 environmental and consumer organizations including itself, Americans Against Fracking and 350.org have delivered President Barack Obama and the BLM nearly 650,000 public comments asking the government to outright ban fracking on such lands.
Bad Comparisons: Economic Value of Recreational vs. Commercial Fishing
Have you heard this one lately? “Recs just play with their food.” This has been a common misconception put out there by some who simply wanted more from any allocation of the resource between the recreational and commercial user groups. The idea was to make sure that those making the allocation decisions looked at the recreational user as simply someone who was having fun, but creating nothing. On the other hand, the image of the commercial user was someone who was feeding a hungry nation and by doing so, created jobs and economic activity. Unfortunately, as wrong as the image is, it has had some real traction since day one. How is that possible? Let’s look at several factors.
Most importantly, the overall economic statistics show a completely different picture. These may vary from region to region and fishery to fishery, but lets look at the numbers in aggregate. Recreational anglers comprise about 97% of the resource users and take about 3% of the resource. However, from that 3% they generate substantially more economic activity than the 3% of commercial users do from the 97% of the resource. Given those numbers it is amazing that every single allocation decision does not go to the recreational user. But they don’t because “recs just paly with their food”. But that message has not seen a lot of promotion.
Saltwater sport fishing makes up a substantial portion of the overall numbers. In 2011, about 9 million salt water anglers fished for almost 100 million days. This activity generated about $13.5 billion in retail sales, over $32 billion in economic activity, about $10 billion in wages, and almost 250,000 jobs. While we are not a big fan of taxes, when they are used to enhance the activity that pays them, they are beneficial. Marine anglers generated $2.3 billion in federal tax revenue and almost another $2 billion to the states. Wow! If the sport fishing industry were a single business, it would be ranked 51st on the Fortune 500 ™ list. If that is the benefit of “a bunch of guys playing with their food,” bring it on.
The economic activity generated by sport fishing does not just benefit the manufacturers of tackle, marine electronics, boats, and motors. It supports many rural communities along our coasts. Fishing is part of their heritage. More than most, they understand the need to maintain healthy ecosystems and sustainable resources. Those two things have formed their history and will maintain their future.
Sport fishing participants love to catch fish both for fun and for a healthy source of protein. They also understand the need to protect and enhance the environments that support fish. They realize that no fish means no fishing.
Anglers contribute to the funding of our nation’s fisheries conservation and environmental improvement in a number of ways. This past year, 2012, marked the 75th anniversary of a conservation funding system that is envied throughout the world. The Sport Fish Restoration and Boating Trust Fund in 2010 generated $390 million from excise tax on fishing tackle and from the transfer of boat fuel tax back to the trust fund. This money is apportioned back to states by a formula based on metrics of fishing activity. License sales in 2010 also generated $657 million used by states to operate their fish and wildlife agencies. Beyond all of that, anglers annually donate over $400 million to a variety of conservation and fishing organizations. That is an impressive tally and one of the reasons that the US has maintained generally robust fish populations and quality habitat.
Okay so the participation and economics should be a slam dunk. There is still the issue of how recreational users are compared to the commercial user. It is an unfair comparison that the recreational user will lose every time. The angler is the end user on the recreational side. They are compared to the commercial user who is one rung up the ladder. The commercial user employs people and sells a product, albeit a product that is given to them. Never is the recreational user compared to the person who walks into the supermarket to buy seafood, but that would be the correct comparison. Conversely, never is the commercial user compared to the tackle shop owner or marina owner, but that is the correct comparison. Those folks employ people and produce a product or service. They are the engine that helps generate the socio-economic benefits from the recreational use of fisheries resources.
This image has to be changed if the recreational industry wants to get its fair share in the allocation battles. So when you hear someone saying, “recs just play with their food.” You can say that recreational users are the ones who pay to play and thereby support the economy and the resource.
Make sure that your Congressional delegation and fisheries managers understand this value!
But the Mid Atlantic Council and NOAA Fisheries need to step up
If you’ve been lucky enough to be there when river herring (bluebacks or alewives) clash with striped bass you know why we call them, “striper candy”. It’s a big bait that attracts big fish, and makes them act really stupid. Of course not only striped bass, but bluefin, yellowfin, cod, bluefish, weakfish and dozens of other predators go nuts over river herring… At least they used to.
Unfortunately, river herring numbers have declined precipitously. While in 2006 NOAA Fisheries listed them as a “Species of Concern”, a 2012 stock assessment recently confirmed river herring are in dire straits. Alewife and bluebacks are anadromous species – spending most of their lives at sea, then ascending unique rivers to spawn. Out of 24 assessed river runs 92% were determined to be badly depleted. A number of runs have dwindled so far that fewer than 100 adults return each spring to spawn. Last year, the National Resources Defense Council submitted a petition to list river herring under the Endangered Species Act, and while NOAA did a full review, they recently issued a statement declining to list, not because they didn’t believe river herring were in trouble, but because they just didn’t have enough data to support it. Which I still don’t understand given the ASMFC assessment and the well-known fact that these fish spend most of their lives at sea. But moving on….
The cause of the decline is heavily debated. There are still those who want to blame a resurgence “ravenous” striped bass, which frankly is silly given the two species’ historical abundance and coexistence, and, well, there aren’t really that many stripers around anymore anyway. No one really argues that pollution and impediments to upriver migrations haven’t played a large part in the decline. Yet despite greatly improving water quality, dam removal, fish passages, and other efforts to restore habitat, not to mention state-imposed moratoria, river herring numbers, at least in the Mid-Atlantic, continue to tank. (Note: there are indeed some runs in New England that appear to be recovering, more on this later).
River herring are managed inshore by the Atlantic States Marine Fisheries Commission (ASMFC). That body has required most state fisheries to shut down; a few continue, subject to very small quotas, under state sustainable management plans. Yet, at sea, industrial fisheries for sea herring and mackerel are still allowed to kill unlimited amounts of river herring, usually taken as bycatch, and most of that is simply unaccounted for. The building consensus is that a lot, perhaps most, of the mortality is happening at sea.
River herring’s demise has been concurrent with the proliferation of mid-water small-mesh-net trawlers. Since the late ‘70s, there has been a significant motivation for US fishermen to capitalize on fisheries for such low-trophic level species, in the form of federal subsidies among other things. As a result, such fisheries grew in size and scope in a relatively short amount of time.
Operating mostly out of New England ports, such trawlers are quite large, with holds that can store over 1 million pounds of fish. They employ an array of electronics to pinpoint and scoop up entire schools by dragging nets the size of a football field with mesh so small little escapes. Apparently, one tow can put 50 tons of fish in the hold. It’s not unreasonable to speculate that a single tow, in the wrong place at the wrong time, could wipe out an entire river’s run, particularly if it’s already depleted.
So, incidental catch is likely a big factor in river herring’s depletion and failure to recover. There is some data to back this assertion up, but not enough to be definitive, and therein lies the problem. Observer coverage of the small-mesh-net fleet is very low. Such observers, 3rd party contractors that sample and observe catch at sea so as to evaluate the composition of a fishery, are vital if managers are to know what goes on on those boats.
Both the Mid Atlantic and New England Councils, to their credit, sought to address this in their Mackerel, Squid, Butterfish and Sea Herring Fishery Management Plans (FMPs) respectively. Last year, despite significant pushback from the industry, the Councils voted to recommend that NOAA Fisheries impose 100% at-sea observer coverage on industrial herring and mackerel trawlers, having industry share the cost with NOAA.
A few weeks ago, however, NOAA Fisheries disapproved the 100-percent observer coverage requirement, rationalizing the decision by claiming the agency had not yet developed a legal way share observer coverage costs. What’s incredibly odd about this is that NOAA fisheries is already doing such observer cost-sharing in Alaska. Upon further clarification, it appears that there is a mechanism for doing this in Alaska that was, many years ago, written into the Magnuson Stevenson Act, but only for Alaska? Frankly, I don’t really understand it. Public/private cost-sharing partnerships are pretty common as far as I know. But I don’t venture to understand the complicated workings of such federal bureaucracies. Regardless, even if they could implement a cost sharing program, the agency claimed it didn’t have the funds even for their part of the additional observer coverage. Honestly, while it certainly isn’t a popular opinion in some circles, I believe that if any industry is granted the privilege of utilizing such large-scale gear to harvest a public resource in such large volumes for profit, then they absolutely should be required to fully fund whatever monitoring is necessary to insure that what they are doing is sustainable, not just in a maximum-sustainable-yield context, but an ecosystem context as well. But moving on…
NOAA fisheries also rejected a requirement that all catch brought to shore in the fishery be weighed, and a limit on “slippage” events where bycatch is dumped at sea before it can be counted. The latter is important, because NOAA Fisheries did uphold the Mid Atlantic Council’s requirement for an annual catch limit/cap for river herring and shad in the mackerel fishery, beginning in 2014. In other words the mackerel fishery would close if it’s determined that such a cap is met or exceeded. Yet the fact that large tows dominated by river herring can be dumped overboard dead before anyone can determine what was killed, seriously diminishes the enforceability of such catch cap. Not to mention, without a significant number of observers for the fleet, it’s pretty difficult to determine if that catch cap is met even without slippage events.
So where does all this leave us? Unfortunately not in a really good place. And it’s more than a little frustrating. The Councils worked hard on both amendments for years. The provisions were fully vetted by the Councils and included carefully considered compromises. In the end they had broad public support. Really, we all thought we had the monitoring/accountability problem solved. NOAA fisheries says they will work with the Councils to develop a solution to the monitoring issue, but I’m not holding my breath. Even if they did figure out a legal way to cost share with the industry, if the money for observers isn’t there, it’s not there.
But there is hope. The Mid Atlantic Council is currently developing an amendment that could add river herring and shad as directly managed “stocks in a fishery” (SIF) to their Mackerel, Squid and Butterfish FMP. Doing so would force NOAA Fisheries to manage and conserve river herring when they are at sea, through the adoption of measures such as Annual Catch Limits, identifying Essential Fish Habitat, and establishing joint management plans in conjunction with bodies such as the New England Fishery Management Council and/or the ASMFC. Whether it moves forward, however, is indeed in question as certainly there is opposition. Making river herring a stock in the fishery (SIF) would require resources, and NOAA Fisheries is already indicating a reluctance to take this on. But there’s a legal mandate here. Federal FMPs must describe the species involved in a fishery, and NMFS and the Councils are required to manage those stocks in need of conservation and management.
That said, there will likely be those who will argue that river herring are not in need of conservation management in federal waters, or that we just don’t know enough about the status of the overall stock to proceed. I think that’s BS! We do know that 92% of the individual river runs are in bad shape. Given all the recent evidence of the species’ decline and the building body of science indicating mortality at sea, I don’t know how that argument could fly. NOAA Fisheries appears to support the catch cap, so that in itself would tell us that they do believe river herring are in need of such conservation and management. Some will argue that the catch-cap is enough, but as mentioned, without observers it is virtually unenforceable.
There will also be those folks who argue that river herring simply don’t need federal management because they are already managed in state waters. That is complete BS also. It seems pretty darn obvious at this point that they are falling through the cracks in federal waters where they spend most of their lives, and where the bulk of the fishing mortality is probably occurring. Again, NOAA Fisheries did support the annual river herring catch cap we passed a couple of meetings ago, so I think it would be strange for them to say they don’t need federal management.
There are those who argue that in-state/in-river barriers to migration are the cause of the problem, and the populations won’t come back no matter what we do in the ocean. That may be true to some extent, assuming such barriers weren’t being removed or mitigated across the coast. Regardless, what SIF designation would do is enable NOAA Fisheries and the Council to identify Essential Fish Habitat (EFH) inshore. When state and federal projects require federal licenses (energy projects, dams, etc.) those agencies would have to consult with NOAA Fisheries, which could stop or require mitigation of potentially habitat-damaging projects. That would indeed be a good thing.
Lastly, industry has been arguing that volunteer bycatch avoidance projects are and will be sufficient. Certainly industry should be commended for such efforts, and they may be working to some extent. However, they are strictly volunteer, and managers should acknowledge that they are not a substitute for binding federal action to reduce river herring bycatch.
There is evidence that river herring can come back if given the opportunity. There have been recent reports of recovering runs in New England as dams and other impediments to upriver migration patterns are removed. There are those who argue that such recovering runs are evidence that river herring are not in trouble and that as long as we deal with inshore habitat issues they will come back. But such anecdotal reports of a recovery are generally restricted to some very specific areas up north, and there’s some speculation that herring from such northern regions don’t spend their lives at sea in the areas small-mesh-net trawlers frequent. And such recoveries are not happening in the Mid Atlantic’s rivers. Regardless of whether the above is true, what the recovery of such local runs shows me is that they can recover. We should be trying to facilitate that recovery, not allowing large bycatch events to set them back again.
As we move forward with the stocks-in-a-fishery amendment, we should acknowledge and stress that we can rebuild this culturally and economically important fish that has historically been a critical part of the marine food chain. And that we can, at least to some extent, control mortality both inshore and offshore. A stocks-in-the-fishery designation would give us the tools to do that. It won’t be easy for NOAA Fisheries, or Council staff, to make it happen, but it’s their/our obligation. This is not entirely new ground. Such stocks-in-a-fishery management models do exist (e.g. salmon in the Pacific Northwest). I would really like to hear more from NOAA Fisheries about how we can do it, instead of reasons why we can’t.
The public has made it more than clear that they want us to restore river herring, and as a key part of the problem becomes clear (bycatch mortality in the sea-herring and mackerel fisheries) the public has put it in no uncertain terms that they want it addressed. States have invested and continue to invest resources while imposing draconian fishing restrictions including moratoria. The Council and NOAA Fisheries have an obligation to their part in federal waters to make sure those efforts aren’t in vain.
If we can restore river herring runs to the Mid Atlantic, in my lifetime, that would be huge, and I think that we can. The Mid Atlantic Council leads. We have successfully rebuilt or are rebuilding every species under our jurisdiction. No other Council can make that claim. Making river herring and shad a stock in one of our FMPs would allow us to do the same with alewives and blueback. And those once epic river herring bass-blitzes will once again come back. We can successfully restore these historical and culturally important species and we will!
What we need now is the strong support of the public, particularly anglers, as we move forward. Stay tuned, and we’ll let you know when and how you can provide such support.
TRCP Heads West, Putting Conservation Issues in Focus
North Dakota, with all of the attention it has been getting because of the energy boom, low unemployment rate and the resulting financial boon, will be getting national coverage of a different kind.
During Sept. 9-12, the Theodore Roosevelt Conservation Partnership is hosting a Western media summit in Bismarck.
The summit will be headquartered at the Ducks Unlimited Great Plains regional offices.
The TRCP group has been around about 10 years, with offices in Missoula, Mont., and Washington, D.C.
Katie McKalip, director of media relations for the group, said one of the missions of the TRCP is to provide a voice for sportsmen and sportswomen in policy making decisions that affect the outdoors — and to ensure they have a place to hunt and fish in the future.
McKalip said the summit will bring writers and reporters from publications such as the Washington Post, Sports Afield, Field and Stream, Outdoor Life and others.
She said the idea is to give an up-close look at the changing landscape that is much of North Dakota, and the resulting challenges not just for outdoor enthusiasts, but for farmers and ranchers.
“Their (sportsmen and women) voice has been historically underrepresented in the law and policy-making process,” McKalip said.
Theodore Roosevelt’s experiences hunting and fishing certainly fueled his passion for conservation, but it seems that a passion for coffee may have powered his mornings. In fact, Roosevelt’s son once said that his father’s coffee cup was “more in the nature of a bathtub.” TRCP has partnered with Afuera Coffee Co. to bring together his two loves: a strong morning brew and a dedication to conservation. With your purchase, you’ll not only enjoy waking up to the rich aroma of this bolder roast—you’ll be supporting the important work of preserving hunting and fishing opportunities for all.