Comments of the Marine Fish Conservation Network on Principles for Ecosystem-Based Fisheries Management
Presented by:
Rodney M. Fujita, Ph.D
Environmental Defense Fund. 5655 College Avenue, Suite 304. Oakland, CA 94618
Tel: 510/658-8008 Fax: 510/658-0630 Email: rod@edf.org
December 15, 1997
Clear goals are needed to articulate principles for ecosystem-based fisheries management. The goals and objectives of ecosystem management remain a little vague, but may fall into two general categories. The first category might include goals relating to the improvement of stock assessments and estimates of maximum sustainable yield through a better understanding of the ecological factors that control fish abundance and distribution. These are already well established goals of fishery management.
The Network's comments touch on several principles relating to this category of goals. However, we are mainly concerned about a second category of goals that are not yet incorporated into fisheries management: goals relating to the protection of whole ecosystems and sustainable fisheries. We offer several principles that relate to these goals.
We are also concerned that ecosystem management may develop along the same lines as more conventional fisheries management. That is, we fear that it may become dependent on the collection of large amounts of data, which may or may not be possible given many different kinds of constraints. Because management decisions must be made in any case, decisions will most likely continue to be based on uncertain data and models, without insurance against management failure, if the evolution of ecosystem management parallels that of conventional management.
We hope that both ecosystem management and conventional management will incorporate robust management tools that are not extremely data-intensive, that increase the chances that fisheries remain sustainable, and that reduce uncertainty.
One way to achieve these goals is to establish networks of no-take marine reserves. Marine reserves should be part of ecosystem management because they directly protect biodiversity and ecological processes, and afford scientists an opportunity to describe what healthy marine ecosystems are like. That baseline will be essential for real ecosystem management. There are also indications that marine reserves can restore and enhance fisheries.
The precautionary approach is another robust management tool that will be key for implementing ecosystem management, if ecosystem management means protecting both fish and the ecosystems they are parts of. While marine reserves can help us hedge against uncertainty, new policy approaches will be necessary to encourage the reduction of uncertainty. Fishery managers intend to conduct more science and collect more data, but too often these good intentions are not acted upon.
One reason for inaction may be that conventional policies reinforce the status quo. For example, the common policy of adopting catch limits near or even beyond the upper end of a range recommended by scientists supports the status quo; the industry is rewarded when the facts are uncertain. In contrast, the precautionary approach creates incentives for reducing uncertainty. A precautionary policy that imposes catch limits near the lower end of the recommended range but that allows catches to increase if justified by better information should motivate industry and managers to invest in more research.
Protecting habitats from the adverse impacts of fishing must be a core principle of ecosystem management. The policy embodied in NMFS's draft Essential Fish Habitat guidance requires proof that certain kinds of fishing damages habitats and also requires a determination that actions to reduce adverse impacts of fishing on habitat must be feasible and cost-effective. This policy would strongly reinforce the status quo. Where is the incentive to gather data on the impacts of fishing, if such data are likely to have adverse economic consequences? A precautionary policy would mandate performance standards aimed at preventing adverse habitat impacts, and allow the industry flexibility in achieving them. While compliance may not appear to be cost-effective or feasible at first, phased implementation of standards often results in cost reductions and increased feasibility as a result of innovation.
In addition to these general comments, the Network respectfully submits some suggested principles for ecosystem management based on the goals of protecting ecological integrity, promoting sustainable fisheries, and promoting healthy fishery-dependent communities. They include:
- Protect all the pieces
- Minimize fishing damage to incidentally caught species and habitats
- Prevent disproportionate fishing effort a few exploited species
- Define overfishing in an ecological and evolutionary context
- Preserve the age structure, sex ratio, and other important characteristics of target populations
- Include non-quantitative factors in stock assessments
- Use environmental/ecosystem information to improve abundance and yield projections
- Define ecosystem health or integrity and then operationalize it with ecological indicators and targets
- Preserve resilience to natural variability
- Ecosystem-based management institutions should cover whole ecosystems
- Implement interdisciplinary approaches to management
We appreciate your consideration of these principles, and stand ready to assist you in any way that we can.
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