Wednesday, May 30, 2012

Un-protected Fish. Were's the P?

In May of 2012, The Atlantic States Marine Fisheries Commission (ASMFC) released the new River Herring Benchmark Stock Assessment.  This comprehensive report concluded that the east-coastwide population is depleted to near historic lows. The full stock assessment report and state specific stock summaries can be found at www.asmfc.org

River herring are the collective term for two very similar fish species alewife (Alosa pseudoharengus) and blueback herring (Alosa aestivalis). River herring abundance throughout Massachusetts has declined to historical low levels. As a result of these declines the Massachusetts Division of Marine Fisheries (MarineFisheries) established a three-year moratorium on the sale and harvest of river herring throughout state in 2005.  In 2008 the moratorium was extended through 2011 because of a lack of recovery of river herring in the Commonwealth.  Since January of 2012 the moratorium has been extended under the oversight of ASMFC.  In addition, the National Marine Fisheries Service (NMFS) has listed blueback herring and alewife as “species of concern”.

The depletion of river herring throughout the Commonwealth that lead to the moratorium can be seen in the Jones River.  From 2005 to 2011 the estimated size of the Jones River herring run was as low as 560 fish in 2008 and only as high as 4,512 fish in 2010.  It is impossible to compare this to historic levels since population estimates were not conducted in the past.  They didn’t need to be since there was never a concern over lack of fish.  River herring were abundant enough to be used as a primary food, bait, and even as fertilizer.  Journals from earlier colonial settlers frequently commented on the abundance of herring in the area.

Despite the historically low population levels and regulatory efforts to protect the species, Pilgrim Nuclear Power Plant continues to impinge large numbers of river herring on the screen of their cooling water intake. In fact Alewife is the third highest species impinged at PNPS.  Based on annual extrapolated totals PNPS impinges an average of 2,885 river herring per year and have been known to impinge as many as 41,128 river herring in a single year.  These excessively high impingement rates have been occurring for decades. This includes well before concerns over the status of the species, but also in very recent years when the vulnerability of the species was well known.  For example, in 2010 alewives were the second most impinged species at PNPS at an estimated total of 12,951 river herring. This is more than three times greater than the total number of fish estimated for the entire 2010 Jones River river herring population.  This is essentially unregulated.  The cooling water intakes are permitted under the National Pollutant Discharge Elimination System (NPDES).  These permits are administered by the federal Environmental Protection Agency and in Massachusetts by the Department Environmental Protection.  Pilgrim's NPDES permit expired about 16 years ago.  EPA and DEP have been allowing the permit to extend, without review, without the explicitly required oversight, and in violation of it's conditions since the 1990's.    So you have to ask ask yourself:  Where is the "P" in EPA and DEP?