If there are no fish at the docks, it is not because there are no fish in the sea.
It is because National Oceanic and Atmospheric Administration regulations prevent catching them.
The rationale for these regulations is to prevent overfishing and to assure rebuilding presumably depleted stocks. How valid are these assumptions?
Let us look back at the facts in full perspective. The fisheries have been self-regulating for thousands of years. Yet, ever since NOAA's rules and regulations have been enforced with greater and greater stringency during the last 20 or so years, we have witnessed one crisis after another.
No, the technology used by the fishermen has not changed that drastically during this time; if anything, the technology has become more sensitive to the ecology of the oceans— bottom trawl nets now have rollers that prevent their scraping the ocean floor.
I do not want to revisit neither NOAA's blatant contempt for Congress and the judiciary, nor any of the complaints concerning the arbitrary application of its rules and regulations, nor its gross mismanagement in procuring and manipulating the numbers.
I would rather go to the bottom of the issue. It is only with some deep digging that the source of the repeated crises reveals itself: NOAA's decisions are taken on the basis of unreliable numbers as they are gathered on questionable scientific premises.
The complex mathematical models developed by NOAA use reams of historical data from the fisheries, such as landing statistics, and sparse data from independent research, such as surveys aboard fisheries research vessels.
The first component is irremediably and inherently biased: Landing statistics are determined by NOAA's policies, not by fish availability.
And what of the rest of the data? Here the criticism is widespread. A recent investigation by the online news aggregator SavingSeafood.com found 11 problems of a highly technical nature — such as measurement of age and assumptions about mortality — that ought to be addressed by NOAA.
Offhand, I can list at least seven self-evident reasons for the discrepancy between the experience of fishermen who find an abundance of fish in the ocean and the results of NOAA's surveys.
NOAA's data are collected by the Bigelow, an ocean vessel whose speed can be higher than that of commercial vessels; so, the timing of trawls can be faster; the displacement of water larger; the shadow cast by the vessel much larger and deeper; the sound of the engine louder. Fisheries scientists, reading the reports of the fishermen, know where the fish were. Fishermen know where the fish are.
Then there are fundamental concerns about surveys in general. Concerns cover the entire gamut of the science used by NOAA, from the definition of the universe to be studied to the formulation of the sampling techniques to be used. A thorough scientific review of the survey methodology used by NOAA for its estimates of stock assessments is in order.
There is a solid science that ought to control the administration of fisheries. This is biology, and biology is overwhelmingly ruled, no longer as in ancient times by the conception of a linear food chain, but by an organic predator-prey relationship.
Even lemmings, even trees, have been found to live within the limits imposed by the rules unearthed by this science of organic biology.
But NOAA has chosen to ignore those dictates for a simple and very understandable human reason: To admit to the fundamental importance of the science of predator/prey relationships would be to admit that all its unconscionable restrictions imposed on the fisheries during the last 20 or so years have been at best unnecessary and at worst counterproductive.
Carmine Gorga lives in Gloucester and is president of The Somist Institute. Dr. Gorga blogs at www.a-new-economic-atlas.com and www.modern-moral-meditations.blogspot.com.
