Correspondence/Amendment 5 Comments - New England Fishery ...

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Incorporating Advances in the Science of Forage Fish into the Benchmark Assessment
Over the course of the past year, there have been several scientific developments that are directly
relevant to the upcoming benchmark stock assessment and how that assessment should be used
to inform management of Atlantic herring.
Scientific work published this year in Fisheries Research by scientists from the Northeast
Fisheries Science Center (NEFSC) examines the performance of a variety of assessment models,
specifically examining species thatarc important as forage.6 The paper illustrates the importance
of using models that explicitly account for predator consumption for forage species like Atlantic
herring. The scientists caution that biological reference points for forage fish derived from
traditional single-species stock assessments are likely too optimistic and can put both the forage
species and its predators at risk.
These findings are reinforced by a separate recent NEFSC study where haddock predation on
Atlantic herring eggs was incorporatèd into the assessment model.T Not only did the haddock
egg predation model more realistically portray actual trends in the herring population, it also
showed that by not taking egg predation into account, the Atlantic herring population may fall
below a critical threshold where recovery would be greatly impaired, even with significant
reductions in fishing mortality.
The Magnuson-Stevens Act's National Standards and supporting guidelines require that fishery
management plans prevent overfishing while achieving optimum yield on a continuing basis. In
determining optimum yield, the Council must take into consideration the benefits of protecting
marine ecosystems, namely maintaining viable populations of target and non-target stocks, and
maintaining adequate forage for all components oi the ecosystem.s Fishery management plans
must also be based on the best scientific information available.' These two papers (enclosed for
your convenience) are relevant to the upcoming stock assessment and should be considered by
the Council as it formulates recommendations for the assessment's terms of reference.
SpecifÌcally, the Council should recommend a term of reference for the stock assessment
team to explicitly incorporate predation mortality (i.e., M2), including predation on eggs,
into the Atlantic herring stock assessment model.
Thank you for your consideration of the views and scientific information presented here. We
look forward to providing additional comments on draft Amendment 5 and the DEIS during the
public comment period.
Sincerely,
e^{"-,¡"*-
Pamela Lyons Gromen, Executive Director
National Coalition for Marine Conservation
Enclosures (3)
6Tyrrell
etal (2011). Theimportanceof includingpredationinfishpopulationmodels:lmplicationsforbiological
reference points Fisheries Research 108 (2011): 1-8.
7
Richardson et al (2011). Role of egg predation by haddock in the decline of an Atlantic herring population. PNAS
108 (33):13606-11 (August t6, z0tll.
'16 u.s,c. 18sl(aX1); cFR so S 600.310(e)(3Xii¡Xc).
'16 u.s.c. 18s1(aX2).