Friday, November 27, 2009

Fish For Friday - The Best Available Science - or Politics?

--- by Jim Lovgren

[This article was written back in January, and forwarded to me by John Enge. It is being reprinted here now because as the White House Oceans Task Force comes closer to completion of their final report, questions continue to arise on the ability of the National Oceanographic and Atmospheric Administration to truly separate science from politics.

[I'm not in agreement with all of John Enge's assertions in the article, but much of what he says is quite viable, based on years of practical experience.]

Much has been made of the Bush administration’s disdain for science, especially in cases where environmental concerns could have an effect on a wealthy campaign contributing corporation’s bottom line. From the butchering of the EPA’s report on global warming, to the interior department’s political interference on endangered species rulings, the Bush administration has shown an almost total disdain for the environment and the creatures that inhabit it, with one glaring exception, the Ocean.

The administration has bent over backwards to curry favor to a well-financed group of ocean advocates, primarily funded by the PEW Charitable Trusts. The National Marine Fishery Service [NMFS], has conducted its own campaign of politically motivated advocacy science, except in this rare instance the administration has seemingly been trying to protect the environment.

So, lets look a little closer at what’s been going on behind closed doors. First thing to realize is that for the last 8 years “Big Oil” has occupied our White house, and that they will do anything to advance their “obscene profits” agenda. No science is safe, since through the machinations of multi-national corporations, and their controls of virtually all forms of media, Global warming can be dismissed as a slight annoyance. Politically, wars can be justified by false accusations of weapons of mass destruction and not the oil reserves that were the real prize. In the case of U.S. fisheries, it appears that the Administration has attempted to atone for their gross contempt of terrestrial ecosystem concerns by placating the environmental industry by saving the oceans. In reality they are just reducing the monetary liabilities of the oil companies by putting the fishing industry out of business.

If you were the leaders of a multi national oil company that wanted to drill on the US East coast, how would you do it? Obviously you would have to remove the impediments to drilling, the fishermen, and the environmentalists.

First, you need to establish a seemingly unbiased funding mechanism to promote your goals. That’s where the PEW charitable trusts come in, a multi billion dollar non-profit, with a seemingly spotless reputation, that was established by Joseph Pew. Coincidentally, Joseph Pew was the founder of Sun oil company, and that is where all the foundation money came from.

PEW claims that they have no connection to big oil anymore, they are just a public policy advocacy group. They don’t mention that half the Board of Directors are Pew family members, and you can bet their investment portfolio is heavily invested in oil stocks. To say that the PEW foundation has no relation to big oil is like saying the Swift boat veterans group were not funded by Republicans.

Using an octopus array of splinter groups to disguise the true source of the funding, Big oil has funded Swift boat attacks by a myriad of ethically challenged “environmental groups”, [ who were only to glad to grab the money], to target overfishing, using PEW funded advocacy scientists who will say anything for a dollar. They also pay a very efficient publicity firm to spread the “news” to the media.

Next, to add some real punch to the plan create an Ocean advocacy group and engage a diverse group of mostly uninformed “experts”, and write an all-encompassing paper describing the global threats to the ocean ecosystem, but conveniently relegate the disastrous effects of oil drilling and spills, to a tiny afterthought, despite thousands of pages of otherwise excellent material.

But if you really want to put fishermen out of business, use the government to do it.

The National Marine Fisheries Service is located in the outhouse on the hill behind the Commerce Department building. They will march to whatever orders come from headquarters. Since the Bush Commerce Department was dominated by multi-national industry concerns, political agendas have driven science. In this case, that agenda was to allow oil drilling on the U.S. continental shelf, in area’s that have been off limits to drilling for over 25 years.

In the waning days of the administration they have gotten their wish, the drilling ban has been lifted. Soon the oil companies will be free to despoil the marine habitat of the U.S. east coast so that they can recover the estimated 600 million barrels of oil beneath it. Did I mention that this year those same oil companies exported over 600 millions barrels of U.S. produced oil to foreign nations? Seems to me that we wouldn’t have to drill here if we kept our oil reserves in our own country.

Besides the potential damage to the fishing industry, and the ecosystem that oil spills and drilling muds would cause, the East coast tourism industry would be devastated. Despite one of the largest coastlines in the continental U.S. nobody goes to Texas to enjoy the beaches, who wants to walk on tarballs? Is this what east coast states want?

Now, here’s where your connections in the Commerce department come in handy. Have your PEW funded minions lobby congress to change the National Marine Fishery Service from an agency that worked to promote a healthy and sustainable fishing industry, into an agency that wants to turn the ocean into a petting zoo. Get the Science centers to create biological targets that are higher then anything ever observed for each species, and then demand that those targets be reached by each species at the same time, a biological impossibility.

The scientists know this is an impossibility, yet they claim it can be theoretically accomplished. If you spent eight years in college to get a masters or doctorate degree in fishery population dynamics, you would say anything the government told you to say, because they are your only chance at employment in that field.

It has been clear to any commercial or recreational fisherman on the East coast for years that the government wants to totally control every movement he makes.[VMS, and AIS tracking devices, overzealous enforcement agents, fishing licenses, etc.]. Part of this can be attributed to the job justification of government workers, the more government workers there are, the more they have to justify their jobs by controlling real workers who actually produce a product that benefits society. History has shown that there is a value to regulation, [ie, “The tragedy of the commons”].

But regulation can go too far, and become far worse a menace then no regulation at all. Especially when that regulation is based on politically influenced science.

As both a fisherman, and a fishery manager, I heard for years fishermen complaining about what they believed to be unjust regulations, because the science was created by people who had no clue about how many fish were in the ocean, they just biannually made their random survey tows, at the wrong time of the year, with obsolete fishing nets, and out of whack towing cables, and then let their mathematicians prove whatever the Department of Commerce wanted proved.

So how bad has the science coming out of Woods Hole, [Northeast Fishery Science Center] been in the last eight years? I’d personally love to subpoena a few scientists and see what they think under oath, because some of the science is so bad that the scientists are either incompetent or they have no integrity. It is so bad in the North East that the fishing industry has had to hire their own scientists to develop alternate science to dispute the government’s findings.

In each of the three fisheries in question, Scallops, Monkfish, and Summer Flounder, the government’s science was found to be sadly deficient. These three fisheries are among the five most valuable Fisheries on the East Coast, and the mismanagement of them has cost the economy hundreds of millions of dollars already. NMFS has a huge annual budget, you would think for the money they spend that they could create accurate science to manage a multi-billion dollar fishing industry in a sustainable way.

Sadly with less then a million dollars of capitol, the commercial and recreational fishing industry has proven how poorly the science was for three critical species. Woods Hole has gone from being the most respected marine science center in the world, to being a joke, a bad one at that.

So lets look a little closer into just what exactly, the NMFS and its partner in crime the NEFSC has been up to in regard to helping their parent agency and its wealthy benefactors in their quest for oil. Ecosystem management has received much attention in the last decade as efforts to rebuild fish stocks have taken on increased public awareness.

The carrying capacity of an ecosystem is the total amount of animals that can be biologically sustained within that ecosystem. There are natural highs and lows of different marine populations, usually caused by environmental conditions, and there are also man-made highs and lows such as the well-documented Groundfish/elasmobranches regime change on the Georges Bank. One thing is certain about ecosystem carrying capacity, there is an upper limit to how much biomass can be sustained, and this is predicated on how much food is available. The composition of the species can and will change, but they cannot exceed the carrying capacity without causing a collapse.

Our management system is based on biological targets that are set for each species that our councils manage. These targets are formulated by the fishery science centers using various complex mathematical equations to come to an educated guess of how many fish of each species should be in the ocean.

The problem is that it is physically impossible for any ecosystem to sustain the rebuilt populations of every fish species at the same time, unless of course, the rebuilding targets are realistic and account for the natural fluctuations of nature. In the case of the Northeast region’s fisheries, the biological targets of many of the managed species are based upon the three-year moving average of the highest observed populations of these species based on the annual trawl surveys. Ask any scientist at the NEFSC if they think it is possible to have all of our fish stocks recovered to the present Biological targets at the same time, and they will tell you that it is impossible.

Yet this is what we are trying to do. There are presently over a billion pounds of spiny dogfish swimming around off the US east coast, three times more then were present in an unfished population in the 1960s, yet we are forced to “rebuild” the population to a level that is unsustainable unless other stocks are not allowed to rebuild. By law that is impossible, the stocks must be rebuilt within a certain time frame or fisheries must be shut down.

This whole system ignores the basic tenet of ecosystem carrying capacity. There simply would not be enough food to feed all of the fish that the NMFS insists should be in the ocean according to their unattainable biological targets. If it’s a consensus opinion of the scientists about the inability to have an ocean full of every species at the same time, then we are not dealing with management by science, but with management by policy.

NMFS insists on ignoring best available science when it comes to biological targets in relationship to ecosystem carrying capacity, yet they are required by law to use it. That is National Standard #2. The fact that they insist on attempting to reach all of these targets at the same time without acknowledging their impossibility or attempting to figure out rational targets in relationship to ecosystem management, and the corresponding carrying capacity of the ecosystem shows a complete disdain of the fishing industry that must suffer the economic consequences of this policy.

This is also ignoring a National Standard, and that is National Standard #8, "Conservation and management measures shall, consistent with the conservation requirements of this act [including the prevention of overfishing and rebuilding of overfished stocks], take into account the importance of fishery resources to fishing communities in order to {A] provide for the sustained participation of such communities, and {B] to the extent practicable, minimize adverse economic impacts on such communities."

So lets look at NMFS poster child for criminal mismanagement, Spiny Dogfish. Using the NMFS' own science, we know that the total biomass of dogfish on the US east coast was around 150,000 MT in the 1960s, and this was as close to a virgin population as you can come by. By the early 1990s the population had increased to over 500,000 MT [over 1.2 billion pounds], as Dogfish and skates replaced the overfished Groundfish stocks on the Georges Bank.

The displacement of the valuable groundfish species was documented by the NEFSC own Steve Murowski. He stated in his paper, Multi species size composition: A conservative property of exploited fishery systems? “Given the current high abundance of skates and dogfish, it may not be possible to increase gadoid and flounder abundance without “extracting’ some of the current standing stock”.

This paper was written in 1992 and a highly effective dogfish and skate fishery developed. [I might add that the little skate population also tripled from 1978 to 1990, and the biological target was set at the highest level for this species also, although they prey on the same food stuff as many groundfish species, including groundfish]. The fishery that developed targeted primarily large females, those dogfish over 80 cm. long, as they were most desired by the market.

During the 1990’s the spawning stock biomass,[SSB, mature females] of Dogfish dropped from 200,000 MT to 50,000 MT causing a chorus of howls about the imminent extinction of Spiny Dogfish. This although the total biomass remained above 400,000 MT, twice that of the 1960s, while the SSB was actually at the unfished level of the 1960s.

At the council level when creating a biological target was discussed, [there still is none], NEFSC brazenly omitted the population levels from the 1960s and told the councils that the population was always at the 1980s level. The council was also told that dogfish eat primarily jellyfish.

When I pressed that issue they admitted that they ate a few fish. Almost every study known to man shows the dogfish to be a voracious predator of bony fishes. [ up to 80% of their diet]. Even as recently as this summer, at the spiny dogfish forum a NEFSC scientist told the audience that the dogfish population was always at the high level it is now at. This is not only providing misleading information, it is outright lying.

Also at that forum Dave Pierce’s presentation brought to light not only how extensive dogfish predation was on other fish species, but also by implication how NMFS has hid the information from the management councils. In a paper by J.S. Link, L.P. Garrison, and F.P. Almeida, called “Ecological interactions between elasmobranches and groundfish species on the northeastern U.S continental shelf: Evaluating predation” published in the North American Journal of fisheries management in 2002, it was disclosed that dogfish predation was almost 20 million summer flounder [ages 0 to 1] for the year 1998. That is close to half of the average annual recruitment of that species. Never once was that figure disclosed to the Mid Atlantic Fishery Management council, despite the controversy surrounding the potential shutdown of that important species because of the stock not being able to reach its 2 times larger then ever observed Biological target.

Yet every year, NMFS was at the management table claiming that retrospective analysis showed a large unaccounted for summer flounder mortality that must be blamed on commercial fishermen’s illegal landings or discards.

Over and over again managers heard how Dogfish were the most studied shark in the ocean, and that due to the depletion of the SSB dogfish would not recover for more then a generation. The most optimistic projections, using zero fishing mortality showed the earliest the stock would recover would be 2018. Most projections put the year to be at least 2030, one even showed never.

Yet here we are in 2008 and the stock has miraculously been rebuilt in 7 years despite a continued fishery, and discard mortality of 20 million pounds a year. Conveniently ignored was the well studied case of the Northwest Pacific Dogfish which was intensively fished to depletion in the late 1940s, yet was healthier then ever by 1960. Scientists there discovered that the population would double every 8 years.

Around 2003 the NEFSC put a new twist into the dogfish dilemma, There was no recruitment of pups, and they are smaller then normal,, OH MY GOD THE SKY IS FALLING! Totally ignoring density dependence science, [maybe the stock knows there are already too many of them, so they slow their reproduction so they don’t compete against themselves], Armageddon projections showed the stocks collapse and close to extinction within our lifetime. Although fishermen, argued that the trawl survey was missing these fish since they spend most of their early years in waters deeper then 100 fathoms, and the annual surveys only made a handful of tows in that water, this unfounded science became part of the rebuilding plan.

I could spend hours pointing out different cases of bad science causing bad management, but Dogfish is the best example, it’s so blatant. How many examples’ can you think of? How can scientists be so wrong? As I said earlier, it’s either incompetence or no integrity.

I believe that criminal actions have been taken by the NMFS to destroy the commercial and recreational fishing industries on the East Coast. When science is doctored to fit a political agenda, wreaking economic devastation to the industries that depend on that science, that is Criminal. These people that have orchestrated this fiasco should be prosecuted.

If you feel this way, then send or deliver this article to your congressman and senator, and tell him you demand justice. With a new administration coming in, it is important to know if they really want the truth about fisheries, or if they will continue the Bush/big oil agenda.

Early returns with the appointment of a recipient of large amounts of PEW oil tainted dollars to the head of NOAA are not looking so good.


AKjah said...

Yes i read the whole thing. Understanding the dynamics of the ocean ecosystem Is a bit much for any one person. There are many who contribute in there niche. Which adds to the whole on understanding. But all that understanding will never trump greed.My son is in the fishing industry. I have no way to tell my son the oceans are dying.

Philip Munger said...


Please stay on topic, or at least come sort of close...

alaskapi said...

The Pacific Salmon Treaty was tweaked as it became apparent that science work done on either side of the US/Canada border could come to different conclusions with the same data... presumably because policy affected folks analyzing data.
In that vein, I have been wondering how it is that we have come to accept so many decisions which are made on in-house science which can't be said to have passed peer the real sense of peer review...?
Sorta the same question as posed here?
Best available science v policy based science? Or v industry slanted science?
How do we regain footing for best available science?

harpboyAK said...

His attack on the Pew Trust funding of conservation groups is bull pucky. The greedy fishermen of the East Coast screwed up the fisheries there, overfishing long before regulation began.

I'm perfectly happy for Pew to fund conservation efforts in Alaska, since there are plenty of other sources to fund research and opposition to offshore drilling. At least the Pew folks are unafraid to go after the Outside trawlers that are continuing to ruin Alaska salmon and halibut fisheries.

It really is time to stop trawling, and require the pollock industry to change to a target pot fishery if they want to continue fishing for pollock.

Philip Munger said...


"At least the Pew folks are unafraid to go after the Outside trawlers that are continuing to ruin Alaska salmon and halibut fisheries...."

Where have you seen evidence that is the case in Alaska? I haven't yet read any documents to suggest Pew orgs are attacking the Bering Sea trawling paradigm.