by Ed Lallo/Newsroom Ink
A renowned economist, working in the field of fishery bioeconomics, has authored ten commandments that the House and Senate subcommittees should follow while reauthorizing the Magnuson-Stevens Fisheries Conservation and Management Act of 2006.
The Ten Commandments on Magnuson-Stevens Reauthorization was written by John Ward to serve as guidelines for politicians and their staffs working on the new legislation to oversee U.S. fisheries Management. Ward is an economist appointed to the Gulf of Mexico Fishery Management Council’s Standing Science and Statistical Committee, as well as its Social and Economic Science and Statistical Committee.
According to Ward, “The reauthorization is all about allocation. The role economics plays in fisheries management is misunderstood by biologists and those who have written past acts.”
The legislation is the primary law governing marine fisheries management in the United States. The law is named after Warren G. Magnuson, former U.S. senator from Washington state, and Ted Stevens, the former senator from Alaska.
The ‘‘Strengthening Fishing Communities and Increasing Flexibility in Fisheries Management Act’’ is the House Natural Resources Committee proposal on updating laws governing fisheries management in the United States. Its aim is to provide flexibility for fishery managers and stability for fishermen, while still maintaining key sustainability programs.
“Uncertainty and risk has resulted in a metric that measures model error associated with the constantly changing stock assessment in the estimation of biomass,” said Ward who has served as a senior economist for the National Marine Fisheries Service’s Office of Science and Technology, Fishery Statistics and Economics Division, “The National Marine Fisheries Services should be required to adopt theoretically based definitions of risk and uncertainty so risk neutral management regulations can be developed and adopted.”
The Senate Natural Resources Committee has yet to release their revision, it is expected sometime later this year.
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Ten Commandments of Magnuson-Stevens Fisheries Act Reauthorization
1. Allocation
It’s all about allocation. Economics in any introductory text is defined as the study of the allocation of scarce resources amongst unlimited wants.
The role economics plays in fisheries management is misunderstood by biologists and those who have written past Magnuson-Stevens Fisheries Conservation and Management Act (MSFCMA) reauthorizations.
Given the recent stress on allocating fishery resources between different commercial and recreational fishers, and other user groups such as endangered species advocacy groups, determining allocation rules should be seen as the primary responsibility of natural resource economists with a specialty in fisheries.
2. Bioeconomics
Bioeconomic models provide multi-disciplinary science based advice that cannot be equaled by individual analyses provided by biologists as in the present management assessment approach. One need only look at the large number of plan amendments and, in the northeast region, the extensive numbers of framework adjustments.
If biological stock assessments were all that is necessary to manage a living marine resource, the management issues would have been resolved by now and Atlantic cod would not be such a debacle for the National Marine Fisheries Services (NMFS).
Even the success of sea scallop management is the result of an unforeseen coincident that occurred because ground fish regulations closed certain fishing grounds.
3. Biomass
Bioeconomic models should be the preferred method when determining the effect of fishery management regulations. Few, if any books with fisheries management in their titles, do not include economics in their text.
National Standard Five states that economic efficiency should be considered but stock conservation needs to come first. This should be changed to economic efficiency shall be considered above all else. That is, benefits shall exceed costs for a management action to be adopted.
Maximum economic yield has a higher biomass level associated with it than that level of biomass that exists at maximum sustainable yield. Higher biomass means a lower cost per fish caught or pound of fish landed even if cost per unit of effort is constant.
4. Optimum Yield
The definition of optimum yield, as maximum sustainable yield adjusted by economic, social, and ecological factors, should be changed to optimum yield as maximum economic yield adjusted by social and ecological factors.
These adjustments need not be stated since these factors are already included in MEY just as are the biological factors. That biomass at Maximum Economic Yield (MEY) is greater than at Maximum Sustainable Yield (MSY) has not been understood in the entire history of the MSFCMA necessitating the inclusion of these adjustment factors in the definition.
5. Cost-Benefit Analysis
Cost-benefit analysis should become the metric for the adoption of fishery management regulations under the MSFCMA. Benefits net of costs, not just benefits, are increased by correcting market failures such as imperfect information (uncertainty) and immobile inputs and outputs (weak, unenforceable property rights for fish in the sea) that reduce values as measured by net benefits.
Despite an extensive NMFS data collection program, the value of recreational fisheries is unknown with input-output model estimated expenditures mistakenly presented as and confused with values. Biologists have assumed many benefits are generated by draconian regulations that have actually increased the costs of recreational and commercial fishing. An example: jobs are termed a benefit when on IRS tax returns owners counts crew wages as costs.
6. Economic Value then Economic Impact
The MSFCMA stated objective is to improve the financial viability and economic performance of the fishing industry. These two overriding goals of fishery management can only be achieved if the true benefits exceed the costs of regulating the fishery. Input output models, and their multipliers, cannot demonstrate that these goals are being met. However, once the value of the fishery has been determined using cost-benefit analysis, their impact on jobs, income, and sales can be calculated using input-output multipliers.
7. Theoretically Definitions of Risk and Uncertainty
Uncertainty is the lack of information concerning the outcome of a future event; portrayed as a percent probability.
If National Standard guidelines on risk and uncertainty were applied to the world, casinos in Atlantic City and Las Vegas would have declared bankruptcy decades ago; everyone who played the lottery would win; and the football team receiving the kickoff could not be determined on the flip of a coin.
The scientific uncertainty defined in the National Standard guidelines has resulted in a modeling error associated with the constantly changing stock assessment in the estimation of biomass. Risk is not a constant value of 0.3 or 0.4 as in the calculation of P* by the NMFS, it is the value of the landed fish that is being bet on the outcome.
NMFS should be required to adopt theoretically based definitions of risk and uncertainty so risk neutral management regulations can be developed and adopted, where the expected value of the outcome is at least equal to the value of that being risked. This requirement goes hand-in-glove with cost-benefit analysis and multi-scientific discipline, bioeconomic modeling.
8. Decentralize Fishery Management
Disband the NMFS by turning the positions and funding over to the regional Fishery Management Councils. Leave a small office in D.C. to review management actions by Councils and to ensure that the legal requirements of all applicable federal laws are being met.
The political portion of the management decision-making process will be relocated to the fishery management councils, where it rightly belongs. Regional fishery management councils can customize fishery research to their region to ensure all aspects of the MSFCMA are met; not just those portions subject to judicial review.
9. Depoliticize Science
Remove requirement, set by the Science and Statistical Committee (SSC) of the regional Fishery Management Councils, that annual catch limits cannot be exceeded in Council allocation decisions.
This requirement currently moves political influence, formerly focused on Council members, to SSC panel members. Currently, non-scientists sit on both the biological and socio-economic panels. Regional Directors attend meetings to ensure their opinions are not only heard, but also followed, in an effort to influence the outcome of what should be a physical and social science analysis and debate.
10. Benefits of Rebuilding Overfished Stocks
Congress has given NMFS a clearly stated goal of rebuilding overfished stocks and ending overfishing. This goal needs to be modified to include rebuilding stocks to maximize net benefits to the fishing industry with consideration given to the non-consumptive user groups, including but not limited to non-governmental organizations concerned with endangered marine species. If this is not accomplished, the costs of fishing escalate and the fishing seasons collapse, with little to show for the excessive costs of fishing caused by these regulations.
Well done John. I can only add that much of the revision work is unnecessary given that EO 12866 has always been imbedded in the NS#1 guideline definition….just that it has been repeatedly attacked and is now left to the last four sentences in the 60 page NS#1 guideline. Its a question of the agency admitting to it.