To: New England Fishery Management Council

Stop Industrial Trawlers From Threatening The Ocean System

I support the New England Fishery Management Council's (NEFMC) decision to explicitly account for Atlantic herring's unique role as a forage fish in the ecosystem when setting catch limits. Herring is a valuable public resource. I commend the Council for recognizing this as an ecosystem issue and engaging your ecosystem-based fisheries management (EBFM) experts.

Although the NEFMC initiated Amendment 8, it is not simply a New England issue. During annual migrations, Atlantic herring journey as far south as North Carolina and as far north as Nova Scotia. Herring have always been an important part of the marine food web throughout their range, but they have become even more important with the decline of other forage species, such as river herring, shad, mackerel, and menhaden. Recent scientific research supports leaving enough forage fish like herring in the ocean to support not only their own population, but also viable populations of other species that depend upon them. Many herring predators are depleted, and keeping enough herring in the ocean will improve the chances of recovery for cod, tuna, whales, and seabirds. I urge the NEFMC to consider alternatives for Amendment 8 that are based on this latest scientific guidance for managing forage fish.

Herring predators have tremendous economic as well as ecological value, contributing to the economy through commercial and recreational fishing for tuna, cod, and striped bass, as well as whale and seabird watching. The NEFMC should consider, and quantify to the best of its ability, this economic value, and recognize that it is dependent on abundant Atlantic herring during particular times of the year and in specific places in the ocean. Many predators are migratory--following prey and finding suitable habitat for mating, nesting, and growing. Amendment 8 should include alternatives that explicitly aim to keep Atlantic herring present in sufficient quantities when and where they are needed most by predators. Amendment 8 should also include options that curtail fishing incrementally as the Atlantic herring population declines, and that stop all fishing for herring below a minimum population level.

Thank you again for embarking on a long-term, ecological harvest policy for the Atlantic herring fishery. This is a significant step toward developing EBFM, which is a stated goal of both the NEFMC and of the National Oceanic and Atmospheric Administration's Fisheries Service. I look forward to seeing the draft of the amendment with a full range of alternatives when the Council releases it for public comment.

Why is this important?

Currently, the limits on the number of Atlantic herring that can be caught are benefiting industrial fishing operations but threatening the Northeast’s ocean ecosystem. We need you to come to the rescue by taking urgent action now.

The New England Fishery Management Council (NEFMC) is in the early stages of developing a policy to change the way catch limits are set for Atlantic herring, a keystone species in the marine ecosystem and an important food source for whales, seabirds, and bigger fish, such tuna and cod. The Council needs to hear from people who care about the ocean ecosystem, not just from the herring fishing industry.

Earthjustice has been fighting for more than a decade to protect our oceans from irresponsible fishing practices, pollution, and habitat destruction. Today, we need your help.

Act now: Tell New England fisheries managers that Atlantic herring are critically important to the ocean, not just to the fishing industry’s bottom line.

Other councils have recognized that forage fish need to be managed differently than other fish. Many marine species that depend on herring for food are struggling after long periods of overfishing and ecosystem disruption. New England managers must ensure that enough herring are left in the ocean—at the right time and in the right locations—to give these herring predators enough to eat and sustain their populations.

Herring predators aren’t just ecologically important; they also have economic value. Tuna fishing, commercial and recreational fishing for cod and striped bass, whale and seabird watching—all these activities contribute to the Northeast’s economy. The NEFMC should consider this economic value and recognize that these activities depend on an abundant source of Atlantic herring.

Take action: Urge the New England Council to protect herring for the long-term health of the ecosystem and the Northeast economy!