In response to international growth of aquaculture in recent years, certain environmental groups have mounted a worldwide campaign to protect ‘forage species’, which in many parts of the world are harvested for fish meal to feed the fish farmed in this growing industry.

The Pacific Fishery Management Council is well underway in developing a California Current Ecosystem Fishery Management Plan, which would address forage needs in a true ecosystem context, including oceanic influences and the population dynamics of all marine life.  The policy and statutes of the State of California already supports this process.

In 2011, the environmental group Oceana spearheaded legislation introduced in the California State Legislature to accomplish essentially the same thing, but applicable only to California state waters, a small sliver of the California Current.

Virtually the entire fishing community, including recreational and commercial fishing associations, harbors and municipalities opposed Assembly Bill AB 1299, seeing it as a fiscally wasteful duplication of existing laws, that would unnecessarily curtail California’s historic ‘wetfish’ industry.

Following are facts about AB 1299:

Coastal pelagic “wetfish” species, such as sardines, anchovy, market squid and mackerels, have contributed the lion’s share of California’s commercial seafood harvest since before the turn of the 20th century.  Wetfish represent more than 80 percent of the total statewide catch each year, and the wetfish industry provides many thousands of jobs in the ports of Monterey, Moss Landing, Ventura, Port Hueneme, San Pedro and Terminal Island, as well as San Diego and San Francisco, and harbors in-between. 

AB 1299 should be considered in context:  California has been recognized by internationally respected scientists as having one of the lowest fishery harvest rates in the world.

From Worm et al, Science 325 (2009) Rebuilding Global Fisheries
“…only in the California Current and in New Zealand are current exploitation rates predicted to achieve a conservation target of less than 10% of stocks collapsed” (i.e. ‘sustainability’ benchmark)

(Fig. 3A)

Green triangle line indicates biomass trend, blue dotted line indicates harvest rate, and dark blue band indicates conservation objective

AB 1299 places unnecessary restrictions on this historic fishery, jeopardizing its sustainability in the future.

  • AB 1299 duplicates existing protections without recognizing nor integrating the ecosystem-based conservation benefits of:                   
    • Magnuson-Stevens Conservation and Management Act (PFMC)
    • California Current System Fishery Management Plan (in development, PFMC)
    • Coastal Pelagic Species Fishery Management Plan (PFMC)
    • Marine Life Management Act (DFG)
    • Market Squid Fishery Fishery Management Plan (DFG)
    • Statewide network of Marine Protected Areas implemented under the Marine Life Protection Act
    • Additional closures and restrictions implemented through fishery regulations
  • AB 1299 identifies environmental risks, none of which are caused by fisheries in CA, yet proposes only to restrict fishing – where’s the link?
    • “overfishing” is not occurring in CA coastal pelagic species fisheries.
    • Virtually NO whole fish are converted to fishmeal in CA.

  • The policy outlined in AB 1299 does nothing to enhance ecosystem-based management. EBM is the goal of current state and federal fishery management policy. Measures proposed in AB 1299 simply restrict fishing without consideration of the resource protections already embedded in existing law.

    • ‘Forage species’ definition targets already well-managed coastal pelagic species.
    • Ecosystem management cannot be carried out with attention only given to a single trophic level in a small portion of a single habitat (in this case ‘forage’ fishes in the epi-pelagic habitat) (Richard Parrish)

  • AB 1299 is an unfunded mandate and duplication of existing efforts – a misguided attempt to curtail CA’s historic wetfish fishery complex in the guise of marine resource protection

  • AB 1299 requires the Department of Fish and Game and Commission to attempt to make findings that are enormously expensive, duplicating current federal efforts, and the proposed policy implies restrictions on sustainable fisheries in California ‘unless and until’ findings ‘prove’ no negative impact on the species or “ecological services” rendered in the ‘larger’ ecosystem.

    • It is scientifically impossible to ‘prove’ a negative finding.
    • AB 1299 would exact inequitable penalties on California fisheries, as most forage species are already managed under the federal Coastal Pelagic Species Fishery Management Plan as well as state law.
    • AB 1299 would cause irreparable harm to California ports and harbors, where coastal pelagic (forage) species comprise essential social and economic benefits to the community.

  • There is no way that a comprehensive forage species conservation and management policy can be adequately addressed without considering the entire California Current Ecosystem (as is currently underway through the Pacific Fishery Management Council). Also required is significant dedicated funding for both the planning team and a permanent monitoring plan to track the ecosystem health of the lower trophic level fishes and pelagic invertebrates as well as oceanic regime shifts.

    • The research required by this bill is already being investigated by NOAA and independent scientists.
    • Marine mammal populations have increased in California during the past several decades, after passage of the Marine Mammal Protection Act of 1972, when fisheries were significantly larger than they are at present, suggesting that the ecosystem was healthy even at the higher exploitation rates that occurred during the 1980s and early 1990s.

  • This bill negates the role of science, and disregards the hundreds of scientists who have spent their lives studying, describing and analyzing the complex ecology of the California Current System.

    • Pelagic species by definition are carried by the currents; their distribution varies wildly from year to year due to their population size, wind and density driven local circulation processes, El Nino events, decadal and regime scale environmental process in the entire Pacific Basin. (Richard Parrish)

  • The evidence gathered over the last century demonstrates that ecosystem management will necessarily be an adaptive process that utilizes monitoring of both environmental and biological processes to determine the current environmental state, and then applies an ecosystem model to determine optimum harvest policies.

    • CWPA has developed a collaborative research program for market squid that links environmental indices (i.e. sea surface temperature, chlorophyll A, ocean currents etc.) to scientific capture of squid paralarvae and local concentrations by area, and is cooperating with state and fishery squid scientists to relate trends to harvest levels over time.

  • The proposed policy jeopardizes already sustainable fisheries without achieving ecosystem management, as it addresses only part of the forage pool in a small percentage of the ecosystem.

    • Virtually all the forage species specified in AB 1299 range throughout the entire California Current Ecosystem, stretching from Mexico to Canada. AB 1299 applies only to California state waters, which extend seaward only three miles from the mainland.

  • The Pacific Fishery Management Council is well underway in developing a California Current Ecosystem Fishery Management Plan, which would address forage needs in a true ecosystem context, including oceanic influences and the population dynamics of all marine life. The policy and statutes of the State of California already supports this process,

  • AB 1299 is redundant and unnecessary.