The American Fisheries Society (AFS) that includes more than 9000 members took umbrage with my piece The Cost of Trout Fishing in the New York Times (NYT) last April. They call my piece inaccurate and complain about fundamental misunderstandings in fisheries management. I can assure the readers that all my facts were meticulously referenced and were carefully fact-checked by the editorial staff at the NYT. I was actually amazed at the amount of behind the scenes work and factual confirmation that went into a short op-ed piece of this nature. I stand by what I said in the NYT and I thought it would be useful to do a little factual checking on the claims AFS made in their editorial.
The AFS editorial seems to intentionally blur the facts through a change in terminology and misdirection with the stocking numbers they use. At the heart of the issue is a somewhat disingenuous tactic and alteration in wording AFS uses to switch the discussion from my focus on native versus nonnative species in the NYT piece, to an argument of hatchery versus wild trout in their response editorial. As AFS is fully aware, wild trout could be either native or nonnative. The National Park Service, U.S. Fish and Wildlife Service and U.S. Forest Service have all taken action to remove non-native trout or prevent their spread with barriers because they are impacting threatened and endangered species, including native trout species. The fact that AFS was unwilling to focus on the topic of native versus nonnative trout stocking is very disheartening.
AFS leads off its editorial disputing the fact that fishing pressure has had and continues to have an important impact on trout populations. Robert Behnke, a.k.a. “Dr. Trout,” THE expert on native trout in the U.S. attributed the presumed extinction of Alvord trout to stocking of nonnative trout, not habitat loss. With regard to Gila and Apache Trout he said in his book Trout and Salmon of North America, “the impact of hybridization with stocked rainbow trout has been the major cause of the great decline in both Gila and Apache Trout.” The U.S. Geological Survey (USGS) data sheet on rainbow trout further support this claim. The problem with cutbows and hybridization of nonnative rainbow and other native cutthroat trout is also well documented. Behnke stated “Appalachian brook trout has been greatly reduced by nonnative trout.” And he said “The introduction of nonnative brown trout and brook trout probably hastened the demise of the bull trout.” To ignore the fact that stocking of nonnative trout hurts native trout and is a function of fishing pressure is naive and misinformed. The simple fact that state and federal hatcheries need to stock 130 million trout every year, many of them nonnative species, highlights the continued roll that fishing pressure plays on native trout populations.
In a fairly interesting twist, AFS and I used the exact same source to document the numbers of annual fish stocking in the United States. In 2008, M. A. Halverson wrote an article “Stocking Trends: A Quantitative Review of Governmental Fish Stocking in the United States, 1931–2004” in the AFS publication Fisheries. I carefully used Halverson’s data to determine the number of trout stocked each year. AFS decided to also lump in bass, pike, walleye, salmon, etc. to report the 1.75 billion fish of all species stocked each year. They then point out that most fish are stocked as juveniles and are very small in size. They conveniently ignore the statement by Halverson that “96% by weight of the fish stocked by the federal government in 2004 were salmonids and more than 40% of the fish stocked by the federal government were rainbow trout.” If we use Halverson’s numbers and also include state hatcheries, 91.6% of stocking by weight is salmonids and 63.7 % of stocking by weight are trout (This total does not include stocking of landlocked Atlantic salmon and Kokanee salmon for purely recreational fishing). Because the total weight of fish produced is a direct function of the amount they are fed and the time fish spend in a hatchery, the weight of stocked fish is a much better measure of the resources allocated to raising these trout than the total number of fish. The AFS decision to focus on numbers of all fish stocked instead of weight of trout, very conveniently hides the fact that the vast majority of rearing and feeding effort at state and federal hatcheries is focused on trout production for recreational angling.
AFS disputes some of the pellet production numbers as well. They claim that reduction fisheries are expected to support modest growth in the future. This subject is an incredibly complex and political issue in itself. In 2011, NOAA and USDA jointly authored a publication (M. B. Rust et al., The Future of Aquafeeds (Silver Spring, MD: NOAA/USDA Alternative Feeds Initiative, November 2010), which made the following statement;
“… as stocks of pelagic or reduction fisheries used for feed, direct consumption, and bait are limited and already fully utilized.”
In particular, the statement “already fully utilized” is important because it indicates that the agencies believed the catch limit was set at the maximum sustainable yield. In 2012, NOAA revised their evaluation of the Atlantic menhaden fisheries. The NOAA Menhaden Fishing Facts Website contains one unambiguous and one ambiguous statement. In particular the website (updated January 2012) clearly states,
“Based on the revised 2009 Atlantic menhaden stock assessment and the new fishing mortality threshold, overfishing is occurring."
The website then contains a very ambiguous, non-committal statement,
“It is unknown whether the stock is overfished. Sensitivity runs of the model in the 2012 assessment update produced conflicting results regarding the overfished status.”
These statements obviously will leave most people completely confused about NOAA’s opinion on the sustainability of Atlantic menhaden harvests taking place at that time (January, 2012). However, policy decisions soon after then clarify that NOAA felt it needed to take action to lower catch limits in the Atlantic (one of the major sources of fish for fishmeal) in 2013. As detailed in this NYT piece and elsewhere, the Atlantic States Marine Fisheries Commission lowered the catch limit by a very large amount, 20% (Jess Bidgood,” Broad Catch Limits Are Put on an Unglamorous but Essential Fish” New York Times, December 14, 2012). In particular, the article states;
“Regulators on Friday voted to reduce the harvest of Atlantic menhaden by 20 percent, placing a broad catch limit on a critical fishery that has until now been largely unregulated.”
Fisheries managers have clearly had recent concerns about the catch limits for some of the reduction fisheries. There are also numerous scientific articles pointing to the general collapse of reduction fisheries stocks in the 1950s and 1960s. I fully support the move from fish meal to vegetable protein in pellets AFS mentions, but until the proposed numbers for 2022 AFS relies on are actually achieved, it is important for informed citizens like myself to express our concerns about using marine species to feed trout raised purely for recreation.
When it comes to feeding these fish, AFS claims a “near 1 to 1” conversion factor for fish. They use this number to suggest that “most of the feed going into hatcheries comes out “on the fin” not as waste.” Of course if fish had an exact 1 to 1 feed ratio they would be no trout excrement. We know that fish poop, so how much higher than “1 to 1” is the ratio? In addition, both uneaten food and mortality outcomes are clear sources of potential nutrient waste. Citing this single number, AFS ignores food that is never consumed by fish and falls to the bottom of pens and fish mortality at hatcheries. At my local trout hatchery, the manager reported an approximate 85% survival rate for fish. That would suggest food was waste for 15% of the fish raised, which then die and are a source of nutrients. When completing my calculation for food input versus stocked fish production, I used a value of 1.2 pounds of food for every 1.0 pound of trout raised (17% of food delivered to hatcheries is potential waste). This is a fairly conservative estimate that originates from a feeding guideline produced by a pellet manufacturer and confirmed with the manager of the large trout hatchery near my home (G. W. Klontz, A Manual for Rainbow Trout Production on the Family-Owned Farm (South Murray, UT: Nelson and Sons, 1991). The main point is that millions of pounds of nutrient waste are produced.
With regard to effluent from these hatcheries, I certainly understand that hatcheries are regulated by the U.S. Environmental Protection Agency, as are all industries with point source discharges including animal feedlots, sewage treatment plants and commercial manufacturers. One key difference is that very few other industries are charged with enforcing water quality standards for their own manufacturing activities. For Connecticut and many other state agencies, the hatchery production and water quality management functions are carried out by the same basic branch of government. More importantly, AFS conveniently ignores the fact that many hatcheries directly release water from hatchery pens without any pretreatment, as long as the concentrations of nutrients in the water adhere to the EPA discharge permits. AFS also readily admits that some hatcheries are out of compliance.
AFS claims that the Food and Drug Administration (FDA) tests medicines to insure they are “proven safe to the environment.” FDA does animal testing in laboratory settings, but this does not ensure that a drug is safe for an entire aquatic ecosystem. According to the FDA, “"Safe" in this sense means that the benefits of the drug appear to outweigh the known risks.” The USGS is the federal agency that raised concerns about the discharge of antibiotics into our nation’s rivers and streams from hatcheries (E. M. Thurman, J. E. Dietze, and E. A. Scribner, “Occurrence of Antibiotics in Water from Fish Hatcheries,” USGS Fact Sheet 120-02 (2002): 1–5.). Antibiotics by their very nature are designed to kill microorganisms. The USGS was obviously concerned that antibiotic contaminated effluent from hatcheries had the potential to negatively impact aquatic ecosystems. I stand by this source.
AFS raises a final point that genetics are considered in fish stocking. Once again, they refer to “wild” fish, ignoring the critical native versus nonnative species issue. AFS also admits that “for fish whose only destiny is the creel, breeding programs are somewhat relaxed.” If we consider again the fact that a massive amount of the hatchery effort in terms of weight of fish raised is focused on instant put-and-take fisheries, the “relaxed” breeding programs and frequent stocking of nonnative trout obviously becomes a more serious issue than AFS would like to admit.
In closing, I was not surprised when the commercial marine fisheries lobbying groups complained about the negative press reduction fisheries received in the NYT op-ed. Industry representatives and their friends in the National Oceanic and Atmospheric Administration hounded me for a couple of weeks until I produced a lengthy response carefully documenting every one of my claims. NOAA responded with a rather no committal statement, “NOAA does not comment on the global status of herring, menhaden and anchovy harvest quantities.” That was the last I heard of that.
Soon afterward, the American Fisheries Society decided to weigh in on my discussion of stocking of native versus nonnative trout and the impact they had on the environment with what seems to be a fairly politically-motivated stance. That response was finally published in august 2015. In doing so, AFS revealed an industry bias that surprised me greatly. Their subtle change in subject highlights the fact that AFS authors’ primary emphasis is on creation of fishing opportunities not ecosystem conservation. They confirm this economic justification by citing revenue and employment numbers associated with angling in the U.S. I understand that recreational fishing produces lots of money for state and federal governments and local businesses. More importantly, these funds are critical to the budgets of many of the agencies who manage recreational fisheries. I am disappointed that a scientific organization like AFS seemed to care more about the economic bottom line than the aquatic ecosystems many of their members study. If money is really the bottom line behind hatchery production, perhaps AFS should argue for construction of more hydropower dams or manufacturing plants with a cut going to state agencies to more effectively generate income along these river systems. Obviously, I am not serious. But this logic highlights the fact that if we use economics as the primary justification for river management decisions, the rivers will suffer. Anglers and concerned citizens need to care about rivers and all the native species they contain, especially if organizations like AFS don’t seem to care.
The AFS editorial seems to intentionally blur the facts through a change in terminology and misdirection with the stocking numbers they use. At the heart of the issue is a somewhat disingenuous tactic and alteration in wording AFS uses to switch the discussion from my focus on native versus nonnative species in the NYT piece, to an argument of hatchery versus wild trout in their response editorial. As AFS is fully aware, wild trout could be either native or nonnative. The National Park Service, U.S. Fish and Wildlife Service and U.S. Forest Service have all taken action to remove non-native trout or prevent their spread with barriers because they are impacting threatened and endangered species, including native trout species. The fact that AFS was unwilling to focus on the topic of native versus nonnative trout stocking is very disheartening.
AFS leads off its editorial disputing the fact that fishing pressure has had and continues to have an important impact on trout populations. Robert Behnke, a.k.a. “Dr. Trout,” THE expert on native trout in the U.S. attributed the presumed extinction of Alvord trout to stocking of nonnative trout, not habitat loss. With regard to Gila and Apache Trout he said in his book Trout and Salmon of North America, “the impact of hybridization with stocked rainbow trout has been the major cause of the great decline in both Gila and Apache Trout.” The U.S. Geological Survey (USGS) data sheet on rainbow trout further support this claim. The problem with cutbows and hybridization of nonnative rainbow and other native cutthroat trout is also well documented. Behnke stated “Appalachian brook trout has been greatly reduced by nonnative trout.” And he said “The introduction of nonnative brown trout and brook trout probably hastened the demise of the bull trout.” To ignore the fact that stocking of nonnative trout hurts native trout and is a function of fishing pressure is naive and misinformed. The simple fact that state and federal hatcheries need to stock 130 million trout every year, many of them nonnative species, highlights the continued roll that fishing pressure plays on native trout populations.
In a fairly interesting twist, AFS and I used the exact same source to document the numbers of annual fish stocking in the United States. In 2008, M. A. Halverson wrote an article “Stocking Trends: A Quantitative Review of Governmental Fish Stocking in the United States, 1931–2004” in the AFS publication Fisheries. I carefully used Halverson’s data to determine the number of trout stocked each year. AFS decided to also lump in bass, pike, walleye, salmon, etc. to report the 1.75 billion fish of all species stocked each year. They then point out that most fish are stocked as juveniles and are very small in size. They conveniently ignore the statement by Halverson that “96% by weight of the fish stocked by the federal government in 2004 were salmonids and more than 40% of the fish stocked by the federal government were rainbow trout.” If we use Halverson’s numbers and also include state hatcheries, 91.6% of stocking by weight is salmonids and 63.7 % of stocking by weight are trout (This total does not include stocking of landlocked Atlantic salmon and Kokanee salmon for purely recreational fishing). Because the total weight of fish produced is a direct function of the amount they are fed and the time fish spend in a hatchery, the weight of stocked fish is a much better measure of the resources allocated to raising these trout than the total number of fish. The AFS decision to focus on numbers of all fish stocked instead of weight of trout, very conveniently hides the fact that the vast majority of rearing and feeding effort at state and federal hatcheries is focused on trout production for recreational angling.
AFS disputes some of the pellet production numbers as well. They claim that reduction fisheries are expected to support modest growth in the future. This subject is an incredibly complex and political issue in itself. In 2011, NOAA and USDA jointly authored a publication (M. B. Rust et al., The Future of Aquafeeds (Silver Spring, MD: NOAA/USDA Alternative Feeds Initiative, November 2010), which made the following statement;
“… as stocks of pelagic or reduction fisheries used for feed, direct consumption, and bait are limited and already fully utilized.”
In particular, the statement “already fully utilized” is important because it indicates that the agencies believed the catch limit was set at the maximum sustainable yield. In 2012, NOAA revised their evaluation of the Atlantic menhaden fisheries. The NOAA Menhaden Fishing Facts Website contains one unambiguous and one ambiguous statement. In particular the website (updated January 2012) clearly states,
“Based on the revised 2009 Atlantic menhaden stock assessment and the new fishing mortality threshold, overfishing is occurring."
The website then contains a very ambiguous, non-committal statement,
“It is unknown whether the stock is overfished. Sensitivity runs of the model in the 2012 assessment update produced conflicting results regarding the overfished status.”
These statements obviously will leave most people completely confused about NOAA’s opinion on the sustainability of Atlantic menhaden harvests taking place at that time (January, 2012). However, policy decisions soon after then clarify that NOAA felt it needed to take action to lower catch limits in the Atlantic (one of the major sources of fish for fishmeal) in 2013. As detailed in this NYT piece and elsewhere, the Atlantic States Marine Fisheries Commission lowered the catch limit by a very large amount, 20% (Jess Bidgood,” Broad Catch Limits Are Put on an Unglamorous but Essential Fish” New York Times, December 14, 2012). In particular, the article states;
“Regulators on Friday voted to reduce the harvest of Atlantic menhaden by 20 percent, placing a broad catch limit on a critical fishery that has until now been largely unregulated.”
Fisheries managers have clearly had recent concerns about the catch limits for some of the reduction fisheries. There are also numerous scientific articles pointing to the general collapse of reduction fisheries stocks in the 1950s and 1960s. I fully support the move from fish meal to vegetable protein in pellets AFS mentions, but until the proposed numbers for 2022 AFS relies on are actually achieved, it is important for informed citizens like myself to express our concerns about using marine species to feed trout raised purely for recreation.
When it comes to feeding these fish, AFS claims a “near 1 to 1” conversion factor for fish. They use this number to suggest that “most of the feed going into hatcheries comes out “on the fin” not as waste.” Of course if fish had an exact 1 to 1 feed ratio they would be no trout excrement. We know that fish poop, so how much higher than “1 to 1” is the ratio? In addition, both uneaten food and mortality outcomes are clear sources of potential nutrient waste. Citing this single number, AFS ignores food that is never consumed by fish and falls to the bottom of pens and fish mortality at hatcheries. At my local trout hatchery, the manager reported an approximate 85% survival rate for fish. That would suggest food was waste for 15% of the fish raised, which then die and are a source of nutrients. When completing my calculation for food input versus stocked fish production, I used a value of 1.2 pounds of food for every 1.0 pound of trout raised (17% of food delivered to hatcheries is potential waste). This is a fairly conservative estimate that originates from a feeding guideline produced by a pellet manufacturer and confirmed with the manager of the large trout hatchery near my home (G. W. Klontz, A Manual for Rainbow Trout Production on the Family-Owned Farm (South Murray, UT: Nelson and Sons, 1991). The main point is that millions of pounds of nutrient waste are produced.
With regard to effluent from these hatcheries, I certainly understand that hatcheries are regulated by the U.S. Environmental Protection Agency, as are all industries with point source discharges including animal feedlots, sewage treatment plants and commercial manufacturers. One key difference is that very few other industries are charged with enforcing water quality standards for their own manufacturing activities. For Connecticut and many other state agencies, the hatchery production and water quality management functions are carried out by the same basic branch of government. More importantly, AFS conveniently ignores the fact that many hatcheries directly release water from hatchery pens without any pretreatment, as long as the concentrations of nutrients in the water adhere to the EPA discharge permits. AFS also readily admits that some hatcheries are out of compliance.
AFS claims that the Food and Drug Administration (FDA) tests medicines to insure they are “proven safe to the environment.” FDA does animal testing in laboratory settings, but this does not ensure that a drug is safe for an entire aquatic ecosystem. According to the FDA, “"Safe" in this sense means that the benefits of the drug appear to outweigh the known risks.” The USGS is the federal agency that raised concerns about the discharge of antibiotics into our nation’s rivers and streams from hatcheries (E. M. Thurman, J. E. Dietze, and E. A. Scribner, “Occurrence of Antibiotics in Water from Fish Hatcheries,” USGS Fact Sheet 120-02 (2002): 1–5.). Antibiotics by their very nature are designed to kill microorganisms. The USGS was obviously concerned that antibiotic contaminated effluent from hatcheries had the potential to negatively impact aquatic ecosystems. I stand by this source.
AFS raises a final point that genetics are considered in fish stocking. Once again, they refer to “wild” fish, ignoring the critical native versus nonnative species issue. AFS also admits that “for fish whose only destiny is the creel, breeding programs are somewhat relaxed.” If we consider again the fact that a massive amount of the hatchery effort in terms of weight of fish raised is focused on instant put-and-take fisheries, the “relaxed” breeding programs and frequent stocking of nonnative trout obviously becomes a more serious issue than AFS would like to admit.
In closing, I was not surprised when the commercial marine fisheries lobbying groups complained about the negative press reduction fisheries received in the NYT op-ed. Industry representatives and their friends in the National Oceanic and Atmospheric Administration hounded me for a couple of weeks until I produced a lengthy response carefully documenting every one of my claims. NOAA responded with a rather no committal statement, “NOAA does not comment on the global status of herring, menhaden and anchovy harvest quantities.” That was the last I heard of that.
Soon afterward, the American Fisheries Society decided to weigh in on my discussion of stocking of native versus nonnative trout and the impact they had on the environment with what seems to be a fairly politically-motivated stance. That response was finally published in august 2015. In doing so, AFS revealed an industry bias that surprised me greatly. Their subtle change in subject highlights the fact that AFS authors’ primary emphasis is on creation of fishing opportunities not ecosystem conservation. They confirm this economic justification by citing revenue and employment numbers associated with angling in the U.S. I understand that recreational fishing produces lots of money for state and federal governments and local businesses. More importantly, these funds are critical to the budgets of many of the agencies who manage recreational fisheries. I am disappointed that a scientific organization like AFS seemed to care more about the economic bottom line than the aquatic ecosystems many of their members study. If money is really the bottom line behind hatchery production, perhaps AFS should argue for construction of more hydropower dams or manufacturing plants with a cut going to state agencies to more effectively generate income along these river systems. Obviously, I am not serious. But this logic highlights the fact that if we use economics as the primary justification for river management decisions, the rivers will suffer. Anglers and concerned citizens need to care about rivers and all the native species they contain, especially if organizations like AFS don’t seem to care.
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