On the morning of June 5th, the Northeast Fisheries Science Center (NEFSC) hosted a Pre-TRAC meeting at the New Bedford Public Library. The TRAC is an international agreement between the United States and Canada under which yearly catch limits for George’s Bank yellowtail, cod, and haddock are determined and allocated appropriately to each Nation.
Attendees at the Pre-TRAC meeting included representatives from industry, non-profit organizations, educational institutions, and state governmental organizations. Unfortunately, there were few fishermen present; however, considering that the meeting was held during working hours it was not surprising that members of a financially struggling industry could not take time off from work to attend. Industry members present and other attendees did voice many concerns of those that were out fishing. The intent of the meeting was to discuss “updated commercial and research survey data” and the findings from the new “empirical approach” meeting that would be applied to the TRAC benchmark assessments meeting to be held on June 23-27 in Woods Hole.
Prior to the June meeting, NEFSC hosted an “empirical approach” TRAC Yellowtail Benchmark meeting in April to “evaluate all relevant data sources with respect to their support for alternative hypotheses on stock status and . . . their directional impact on catch advice.” With NEFSC pledging that the “empirical approach” meeting would be new, innovative, inclusive, and transparent, there was much hype leading up to the April “Empirical Approach” meeting. NEFSC has been criticized in the past for a lack of transparency, collaboration, and using limited and stale data sources because it utilized only two government owned and operated Bigelow trawl surveys and one Canadian trawl survey to assess George’s Bank yellowtail stock when in fact there are several more studies and assessments completed throughout the year by educational institutions and cooperative research. It is an understatement to say that the fishing industry and stakeholders were excited and supportive of NEFSC’s “empirical approach.” They saw it as an important step forward in increasing collaboration, transparency, and cooperation between researchers to improve upon science and ensure that all data is considered.
So, what is the result of the new “empirical approach?” At the close of the April meeting, several studies presented revealed that the yellowtail biomass was in the range of 4,000 to 11,000mt. This data and applying the most conservative regulatory standards, suggests that the yellowtail catch advice should be 1,000mt. However, on June 5th NEFSC presented 553mt as its likely yellowtail catch advice to be presented at the TRAC meeting.
The catch advice is based on three surveys: NOAA’s spring and fall Bigelow surveys and Canada’s one winter survey. Other scientific studies, such as cooperative research and the UMass Dartmouth SMAST’s video trawl survey, have not been factored into the catch advice. When pressed to answer questions about why other sources of data were not factored in, or if the agency had tried other methods to analyze the data, the standard answer given was that NEFSC has not had a chance to incorporate the other empirical data. NEFSC’s explanation of “not having the time” has been found to be insufficient justification for not reviewing such data and its effect on catch advice (See Guindon v. Pritzker).
The TRAC agreement does admittedly state that catch advice will be based on the three government surveys; however, the agreement is amendable. It is highly unlikely that NEFSC’s Canadian counterparts would be opposed to improving upon the science and issuing more appropriate and accurate catch advice. By not incorporating and ignoring the contrary data from the “empirical approach” meeting, the 553mt yellowtail catch advice will raise questions about whether this advice is in fact based on the “best scientific information available” or simply following NEFSC’s on-going bureaucratic agenda.
NEFSC further attempted to justify its catch advice by reasoning that because only 35.6% of the George’s Bank yellowtail quota was landed in 2013, it must necessarily follow that the yellowtail stock biomass is low. Audience members offered several reasons for this low landed yellowtail quota. First, that several fishermen held onto their quota until haddock season so that they could harvest haddock while not worrying about avoiding yellowtail, but weather was not favorable for fishing during the overlapping seasons. The second reason offered was that many fishermen are avoiding yellowtail hotspots because they fear running into large amounts of yellowtail and exceeding their quota. These reasons were generally brushed aside by NEFSC with an answer that these reasons are economic and are not studied by the presenters.
Ironically, an exemplification of why NEFSC’s reasoning that if landings are down, then the stock biomass must be low, is flawed was apparent in its haddock presentation. Both cod and haddock stock biomasses were also discussed at the Pre-TRAC meeting. Similar to yellowtail, the concluding remarks about cod were that only 463mt were landed in 2013 and therefore, cod stocks must be overfished. However, when it came to haddock, despite only 15.2% of the quota having been landed in 2013, the same reasoning was not applied. NEFSC attributed the low landings to flawed management measures because NEFSC stock assessments show haddock biomass is healthy.
In sum, on the one hand and despite contrary data regarding yellowtail stock biomass, NEFSC reasons that when cod and yellowtail landings are down, it must mean that biomass is low. On the other hand, NEFSC maintains that because its science shows healthy haddock stocks, when haddock landings are down it is not due to low stock biomass and must mean that management measures have failed. NEFSC’s hypocritical and flawed reasoning exemplifies why it must incorporate contrary, and potentially superior, data from the “empirical approach” meeting in its catch advice for George’s Bank yellowtail.
The International TRAC meeting is coming up on June 23rd. NEFSC still has an opportunity to make a fundamental change and utilize the contrary data presented at the “empirical approach” meeting in devising its yellowtail catch advice. If the NEFSC is attempting to be transparent and to build public trust, then its TRAC team should present both the results of the three governmental surveys and the contrary and probably superior biomass data from the “empirical approach” meeting. Presenting all data and catch advice options will lead to the final decision makers being fully informed to determine the “best scientific information available” and establish better, more reliable total catch advice for both Nations.
This letter was printed in the Gloucester Daily Times on June 21, 2014.