The nation’s largest scallop industry organization has found NOAA’s approach to assessing the status of yellowtail flounder to be virtually worthless and urged the agency to scrap its commitment to “computer models” in favor of “field research.”
The four-page, single-spaced letter to Bill Karp, the newly appointed director of the Northeast Fisheries Science Center, by attorneys for the Fisheries Survival Fund includes a harsh, detailed analysis of government’s effort to determine the status of the stock.
A staple of the groundfishing fleet and bycatch in the scallop trawls, the yellowtail founder is essential for different reasons to the region’s leading commercial ports, Gloucester and New Bedford.
The July 13 letter to director Karp by attorneys Drew E. Minkiewicz and David E. Frulla, with the Washington, D.C., office of the firm Kelley Drye & Warren, repeatedly emphasized the intent was not to pressure the government for a larger allocation of yellowtail.
The National Oceanic and Atmospheric Administration has recently approved a novel arrangement, allowing scallopers to give some of their bycatch allocation to the groundfishing fleet to help the boats avoid an early shutdown for exceeding their yellowtail catch limit. In exchange, NOAA has agreed to indemnify the scallopers should they exceed their yellowtail allocation.
The agreement was improvised last month after NOAA announced dire yellowtail findings in the midst of a generally pessimistic set of assessments of the Georges Bank fishery, and in the immediate aftermath of a deeply discouraging benchmark assessment of Gulf of Maine cod, which has pushed the inshore fishery toward a possible shutdown next May. Twelve New England senators and representatives — including Congressman John Tierney — wrote to NOAA on July 11 asking for extraordinary permission to allow the inshore fleet to reduce its landings of cod this year, and shift the uncaught allocation into 2013 to keep most of the boats out of Gloucester and elsewhere working.
The Massachusetts Marine Fisheries Institute, headed by Paul Diodati, the state director of marine fisheries, and Brian Rothschild, a marine scientist at University of Massachusetts Dartmouth, also have been highly critical of NOAA stock assessments, and in the wake of the cod and yellowtail crises offered in writing to work with NOAA on an “end-to-end” review of what’s gone wrong.
“At the root of most of the problems is a lack of confidence that the industry has in stock assessments and research vessel survey indices,” Diodati and Rothschild wrote to NOAA’s deputy administrator in late June.
Karp wrote back on Thursday that NOAA has “a high degree of confidence in the integrity of the our assessments” and proposed a workshop in 2013.
Minkiewicz and Frulla, however, wrote to Karp after attending a meeting of the Canada-U.S. Transboundry Resource Assessment Committee, a group that jointly manages the stocks that cross the border dividing the nations’ sectors of Georges Bank.
They noted that NOAA has continued to modify its modeling assumptions regarding the status of yellowtail to an extent that the entire effort now is discredited.
“Fishery Survival Fund cannot agree with the use of implausible assumptions to mask the unknown aliases that are causing the problem as a basis for catch advice,” the attorneys wrote. Key to their arguments is a continuous “retrospective pattern,” that is evidence that the status of the stock predicted in the model needed to be negatively modified.
This retrospective pattern behind the yellowtail computer modeling has persisted for a number of years. Quoting the chairman of NOAA’s Retrospective Working Group in a 2008 report that “a strong retrospective pattern is grounds to reject an assessment model as an indication of stock status or the basis for management advice,” Minkiewicz and Frulla asked whether NOAA intended to follow its own advice.
“If the model is not capable of accounting for the unknown aliases,” they continued, “the answer is not to put one’s head down and go forth into that statistical night; rather, it is to accept the limitations of the model and acknowledge the obvious: We are currently in a place that is beyond the capability of the model, making the model no longer useful for catch advice.”
Absent a valid assessment model, they urged NOAA instead to turn to trawl survey and catch indices from the landings as “as the proper scientific course of action as an interim measure until a reliable assessment is made available.”
“The (Fishery Survivial Fund) does not wish to enter into a contentious fight with (NOAA Fisheries) over the status of Georges Bank yellowtail flounder,” Minkiewicz and Frulla wrote in their conclusion, “but we cannot and will not sit back passively and accept catch advice that is based upon an indefensible and ultimately arbirtrary assessment.”
Karp answered in a prepared statement released to the industry website SavingSeafood.com.
“The poor condition of the stock over the past decade indeed confounds attempts to quantify current condition or make projections with confidence, although trends in some characteristics are strong and consistent,” he said. “This uncertainty was widely discussed during the bilateral assessment meeting and will be reflected in the summary and final reports, which the U.S. would not unilaterally revise.
“How this information will translate into management advice remains to be seen,” Karp added, “but some admittedly tough decisions will have to be made by U.S. and Canadian fishery managers in the Fall in order to set 2013 quotas.”
Richard Gaines may be contacted at 978-283-7000 x3464 or firstname.lastname@example.org.