The letter below was distributed to many tackle store owners and other interested parties. Many tackle stores are receiving misinformation and threats. Any threats to restrict the supply of bait to tackle stores or raise the price will surely backfire on the bait industry. It is illegal to price fix within an industry. It is also illegal for a trade association to boycott. We support the right of the bait industry to do business and to voice their concerns in an appropriate way.

It is our position that this legislation in fact actually protects the bait industry and allows for future growth while protects the resource. Claims by the bait industry that they will not be able to harvest enough bunker if they are forced out beyond .6 nautical miles are false. That is the same claim that the reduction boats made in 1990 when they were moved to one nautical mile. The first year the regulation was implemented (moving them beyond one nautical mile) the reduction boat had their largest catch in many years.

Please read the letter below, provide a copy to your local tackle store owner and be prepared to discuss its contents. Tackle store owners should report any threats to appropriate law enforcement authorities both state and federal. You proved how effective you are when you wrote and called about the eel legislation. Now you need to repeat this work to help us get this crucial legislation passed. Without your help these bills will not be passed. Additional information including the charts and graphs developed by the Menhaden Project is posted on our website.

I have again included a sample letter and the Menhaden Fact Sheet. You need only tell your legislator that you live and vote in this district, you support the JCAA position on Menhaden and you want them to vote yes on S722/A1827. This bill may well reach committee before the end of May and may reach the Senate floor for a vote in June. Your action is needed now! If we don’t take action now to protect the resource, there will be permanent damage to the ecosystem and to stocks that feed on bunker, there will be no bait for us (tackle stores, party & charter boats and recreational anglers) and there will be no bunker for the bait industry. This legislation protects us all.

Why should you support Bills S722/A1827 (The Menhaden Protection Bills) This letter is to correct the misinformation being put out by representatives of the commercial industry warning and, at times, threatening business owners like yourself about long overdue proposed legislation aimed at protecting menhaden stocks from overfishing. There has been talk of no bait for your business needs and other preposterous claims that simply aren’t true and can not be supported by the facts. Please take a minute to read this letter for a better understanding of what is being done and why.

The proposed legislation is aimed as much at protecting the bait industry in New Jersey waters as it is to protect the stocks of menhaden from vastly increased exploitation rates. The legislation’s center piece is the removal of large reduction boats from state waters. This will make it easier for bait harvesters to maintain their dramatically increased catches of recent years, while assuring businesses like yours that there will be a sufficient and uninterrupted supply of bait for your customers.

On February 26, 1998, Senator Andrew Ciesla introduced S722; a bill is designed to protect menhaden stocks while allowing New Jersey’s commercial bait fishery to expand within safe and sustainable levels. All fishing by reduction boats would be eliminated within state waters. Large reduction boats are responsible for the largest percentage of the menhaden harvested in New Jersey, a minimum of 60% to 70% of the total annual catch. The bill also prohibits the harvest for any purpose by mobile gear in bays and nursery areas where menhaden need the most protection, and increases the distance from the beach netting can occur for bait to create a safe corridor for immature menhaden. Senator Louis Bassano and Senator Robert Singer are cosponsors.

Assembly Bill A1827, an identical companion bill, was introduced by Assemblymen James Holzapfel and David Wolfe.

This legislation was introduced as the result of the work done by the Menhaden Project, Jersey Coast Anglers Association, New Jersey Federation of Sportsmen, the Recreational Fishing Alliance and many individuals and groups who are concerned about the conservation of menhaden and the problems overharvest presents. This has been an important issue for JCAA since the association was formed. Previous attempts to remedy this problem have been little more than Band-Aids, not solutions. With this legislation, there is finally an opportunity to develop a comprehensive, long term solution that will offer some protection to the stocks while allowing the bait industry to not only maintain its historic catch levels, but expand significantly. This bill will not put the bait industry out of business, but rather allow participants to maintain their already increased harvest by removing reduction boats from state waters.

In addition, it eliminates purse seining in Raritan Bay, which is essential to protect the stocks. In 1991 there was only one purse seiner working the entire state and that was in Raritan Bay. Since this captain had worked there for many years, regulations developed at that time did not eliminate him. Now there are four new boats working Raritan Bay aided by spotter planes. They have dramatically increased the catch, which is detrimental to the ecosystem of the bay and tributary rivers. Raritan Bay is a nursery area for many species that depend on menhaden to support their rapid growth as juveniles. Since this bill eliminates the reduction boats, the boats currently fishing Raritan Bay can move their operations to the ocean. This will allow them to maintain their businesses and actually increase their catch, but eliminate the negative impact created by fishing in Raritan Bay. This legislation does not eliminate existing pound nets, only the impact of mobile gear.

As recently as 1989, the commercial bait suppliers were harvesting all the menhaden New Jersey’s bait dealers, party and charter boats needed with only one purse seiner and two pound nets. They harvested just over 1 million pounds and everyone’s needs were filled. In 1990, the harvest jumped to 7.8 million pounds with six permitted bait boats and the catch has increased by orders of magnitude ever since. In 1995, the harvest was 35.5 million pounds and there were 29 permitted bait boats, and in 1996, 36 permitted bait boats harvested 33.7 million pounds. New Jersey’s bait needs have not increased dramatically since 1989, while bait harvest has increased from 1 to 33 million pounds. So where has all the additional bait been going? To feed the crab pots in Chesapeake Bay and the lobster pots and the General Category bluefin tuna fishermen in New England.

While the bait harvest was growing in leaps and bounds, the reduction boats were still harvesting the overwhelming majority of the menhaden taken from state waters, 77% in 1995 and 66% in 1996. This bill will prevent the harvest of menhaden by the reduction industry and allow the vastly increased number of bait boats to harvest the menhaden the reductions boats were catching further off the beach, while protecting the nursery areas, bays and estuaries where menhaden have become increasingly scarce. These statistics come directly from New Jersey DEP, the Atlantic States Marine Fisheries Commission and the National Marine Fisheries Service and have all been documented.

The bill you need to support, S722, is available on the JCAA website and additional information is posted in the May Newspaper and under Hot Topics. You will be kept informed of any changes made to the legislation. If you need more information, please contact Tom Fote at the Jersey Coast Anglers Association.

Tom Fote
Legislative Chairman
Jersey Coast Anglers Association
New Jersey Federation of Sportsman's Clubs
Phone 732-270-9102
Fax 732-506-6409
Email tfote@jcaa.org

Ref. ASMFC – Menhaden Review

Age 0
Landings-1993/1996, Lowest 4-Year Period Since 1970
Recruits-1995, Lowest Ever Recorded, 1996 Lowest In 29 Years

Age 1 Recruits
1996 – Lowest Level Ever Recorded – 1955, 40 Years
1996 – 1.1 Billion, Below 2.0 Trigger
3 Year Average – Below Trigger – Downward Trend Since 1985

Age 2 Recruits
1996 Lowest Level Since 1972 Downward Trend Since 1983

Age 3 Landings
At Or Above 75% Median For 4 Years, High Level Of Adult Fish

Growth of Inshore Bait Industry

1989 -- 1.0MM 1993 - 26.7MM
1990 – 7.8MM 1994 – 37.5MM
1991 – 15.4MM 1995 – 35.3MM
1992 -- 25.3MM 1996 – 33.7MM

Percent of N.J. Landings by Reduction Boats

1990 – 90% 1995 – 77%
1994 – 43% 1996 – 66%

Bait Harvest Zone I – Sandy Hook/Raritan Bay

Year         % of Total Bait:     Million Pounds

1994 10%                             3.
1995 7.6%                     2.6
1996 13%                             4.4

In Shore Nursery Areas For Forage And Predator Species Are Being Over Fished. Ref. – J. Amer. Fisheries Soc. 124:520-537, 95

In the fall of 1995, a new cooperative state-federal marine and coastal fisheries data collection program, the Atlantic Coastal Cooperative Statistics Program (ACCSP), was formed. The intent of the ACCSP is to design and implement a cooperative state-federal marine and coastal fisheries statistics program that adequately meets the needs of fishers, scientists, and fishery managers. This program is a joint federal-state partnership with members from each coastal state, from Maine to Florida, and the Commonwealth of Pennsylvania; the District of Columbia; the National Marine Fisheries Service; the New England, Mid-Atlantic and South Atlantic Fisheries Management Councils; the U.S. Fish and Wildlife Service; the Potomac River Fisheries Commission; and the Atlantic States Marine Fisheries Commission.

This new data collection and management program will begin this fall. The ACCSP will provide a single commercial data collection approach for all management agencies along the Atlantic coast, increase the quality of recreational fisheries data collection coastwide; and house both commercial and recreational data in one location for easy access by managers and fishermen.

The ACCSP wants to develop a universal sampling frame for all Atlantic Coast recreational anglers (boat and shore), but realizes that this will take some time to implement. Therefore, the ACCSP plans to use the current system, Marine Recreational Fisheries Statistics Survey (MRFSS), with some planned enhancements. The program plans to

1. Increase sample sizes;
2. Sample in tidal and freshwater areas to collect more data on anadromous species such as American shad and striped bass;
3. Increase coverage to non-coastal and inland states to collect more data on out-of-state anglers; and
4. Evaluate other sampling methods such as long-term telephone panel surveys and license sampling frame.

For the "for-hire" fisheries (charter/party boat), the ACCSP is looking at several different data collection methods for estimating catch and effort that could eventually replace the current method (MRFSS). The ACCSP will also develop a comprehensive listing of all for-hire vessels.

Socioeconomic data will be collected for commercial, recreational and for-hire fishermen.

For more information about the ACCSP you should contact: Connie Young-Dubovsky, ACCSP Program Manager, 1444 Eye Street, NW, Washington, DC 20005; telephone: (202)289-6400; fax: (202) 289-6051; Email: Connie_Youngdvbovsky@fws.gov.

Comments on the design of the ACCSP program should be sent to Connie Young-Dubovsky at the above address before June 1, 1998.

Connie Young-Dubovsky
ACCSP Program Manager
ASMFC
1444 Eye Street, N.W.,
Sixth Floor
Washington , D.C. 20005

Dear Ms. Young-Dubovsky:

The following are the Jersey Coast Anglers Association (JCAA) comments on ACCSP, Technical Source Document IV. JCAA agrees with the goals and objectives of the ACCSP. However, as this document stands, the recreational fishing industry is being short changed. At the onset of the program, we were led to believe that this program would not be the status quo, but that a new system would be put in place for both commercial and recreational fishermen. It seems that the ACCSP is implementing many new programs for the commercial sector, but doing very little for the recreational fishing industry. We agree with many of the ACCSP Fisheries Statistics Advisory Committee recommendations.

For the recreational catch/effort data collection program, a unique identifier should be developed for private/rental and for-hire vessels. There is no mention of asking for the number of rods or lines in the water and this should be a minimum data element that is also collected.

A web-site or some other method should be developed so recreational anglers and for-hire captains can access catch by area data so that they can verify that these catches are accurate.

Current plans are to use the present MRFSS system to collect catch/effort data for recreational anglers. We believe that several pilot studies should be implemented to investigate other techniques or methods for collecting recreational data. New and innovative technologies should be attempted and compared to MRFSS.

JCAA feels strongly that an adequate at-sea observer program be developed that will collect bycatch/discard data for all commercial fisheries.

The ACCSP Fishery Statistics Advisory Committee recognized that the biological review panels are an extremely important component and should have representation from state, federal, council, commission, university, and recreational and commercial fishing industry levels. We agree with their recommendation.

The proposed recreational socioeconomic program is very weak and we agree fully with the recommendations made by the ACCSP Fisheries Statistics Advisory Committee that "recreational social and economic data collection be brought to the same quality and confidence levels as the commercial program." There is no mention in this document of plans to collect socioeconomic data on the recreational fishing industry (ex. Bait/tackle dealers, retail businesses and etc.). How can you also ignore fishing communities that have developed around recreational fishing areas? For example, Seaside Heights and Park , NJ where motels and restaurants closed after the summer tourist season now remain open for the recreational striped bass fall fishery bringing in added revenue. The ACCSP must also include studies of recreational fishing communities and the impacts those fishing regulations will have on these regions. An inventory of businesses that depend on recreational fishing and local recreational fishing communities should be developed and a social impact assessment conducted.

We also agree that efforts should be made to reach marginal and subsistence user groups. JCAA is also questioning whether the socioeconomic add-on to MRFSS will be adequate to gather data on all target species and various modes.

For the Metadata Section, we agree with the ACCSP Fisheries Statistics Advisory Committee that the role marine mammals are having on fish populations and predator-prey interactions should become part of this section.

It is time to fix the existing data collection and storage systems for the recreational fishing industry. The JCAA is in favor of changing the existing data collection system. However, we would like to see the points addressed in this letter implemented in the ACCSP Technical Source Document IV, so the recreational fishing industry is given proper weight in the process. JCAA would like to thank ASMFC for providing us the opportunity to comment on the ACCSP.

The meeting will be held at the Washington Dulles Airport Hilton Hotel Herndon, Virginia from June 8 - 12, 1998. The preliminary schedule is listed below. This is subject to change. You should call ASMFC ( ) to check on exact meeting times.

Monday, June 8, 1998

8:00 AM - 10:00 AM--Atlantic Menhaden Mgt.Bd.
Review and approve 1998 Atlantic Menhaden Advisory Committee report; review and approve Internal Waters Processing applications for 1998-99; Florida request to amend Fishery Management Plan

10:00 AM – Noon--Habitat Committee
Review of activities; Commission Essential Fish Habitat Policy; Habitat and Fishery Management Plans Committee report; program planning

1:00 PM - 3:00 PM Legislative Committee
Review of 105th Legislation/Develop positions; discussion of Aquatic Resources Trust Fund (Wallop-Breaux) improvements; review of lobbying activities regarding Atlantic Coastal Fisheries Conservation and Management Act funding

1:00 PM - 5:00 PM--Law Enforcement Committee
Updates on: striped bass enforcement and report; Committee member involvement on fisheries management boards; Atlantic Coastal Fisheries Conservation and Management Act funding; on implementation of Atlantic Coastal Cooperative Statistics Program; and Agency Reports. Discussion of interjurisdictional enforcement issues between state and/or federal enforcement agencies - questions for NOAA General Counsel for enforcement and litigation;

2:00 PM - 5:00 PM-Horseshoe Crab Technical Com.
Update on stock assessment (data analysis); review public hearing draft

3:00 PM - 5:00 PM Tautog Management Board
Review and discuss states’ annual tagging reports

Tuesday, June 9, 1998

7:30 AM - 9:00 AM-Legislators & Governor’s Apt.
Reports from Legislators and Governor’s Appointees (LGAs) representatives serving on other Commission committees; LGA subcommittee recommendation on LGA representation on species management boards; discussion and scheduling of Legislators meeting during August Meeting Week; status of Chair’s appointments of LGA to Menhaden Board

7:30 AM - 11:00 AM-Management & Science Com.
Coordination of nearshore trawl surveys; development of tagging protocols; fish health issues; fish public health advisories resolution

8:00 AM - 5:00 PM-Law Enforcement Committee
9:00 AM - 10:30 AM--Winter Flounder Mgt. Board
10:30 AM - 12:30 PM Summer Flounder, Scup & Black Sea Bass Management Board
Discussion of Black Sea Bass Quota System; update on the Massachusetts scup situation; long term direction of the Summer Flounder Fishery Management Plan

11:00 AM. - 1:00 PM Sturgeon Advisory Panel
Discuss final draft of Amendment 1

1:00 PM - 3:00 PM-American Eel Mgt. Board
Progress report from Plan Development Team; Election of Vice-chair

1:00 PM - 3:00 PM-Horseshoe Crab Advisory Panel
Update from Technical Committee; review public hearing draft

3:00 PM - 6:00 PM Quality Fishing Workshop
6:00 PM - 8:00 PM RECEPTION

Wednesday, June 10, 1998

8:00 AM - 11:00 AM Shad and River Herring Management Board
Technical Committee report on peer review comments; discuss public hearing draft of Amendment 1

8:00 AM - 6:00 PM-Management & Science Com.

11:00 AM - Noon General Session

Noon - 2:00 PM Advisory Committee

2:00 PM - 4:00 PM Sturgeon Mgt Board
Discuss final draft of Amendment 1

4:00 PM - 6:00 PM Horseshoe Crab Mgt. Board
Updates from the Technical Committee and Advisory Panel; review public hearing draft

Thursday, June 11, 1998

8:00 AM - 1:00 PM ISFMP Policy Board
FMP update; Board meeting process - discussion on improving efficiency of process; Board/Section organization for FMPs; Atlantic Sturgeon FMP Approval; MSC report; Law Enforcement Committee report; Atlantic Coastal Cooperative Statistics Program report

1:30 PM - 3:00 PM Executive Committee

3:00 PM - 4:00 PM Business Meeting

I have been appointed the Governor’s taskforce on how to reduce mercury contamination in our environment. As you know many freshwater lakes and some saltwater species are the subject of advisories on mercury contamination. Governor Whitman has put together a taskforce to make specific recommendations to reduce the amount of mercury that is entering the ecosystem. Not all of the mercury in our system originates in New Jersey so this taskforce will be looking beyond our borders and working with other states. The Northeast and Canada have a workgroup to look at this issue because of warning signs in our current environment. We cannot afford to wait until this problem gets any worse. This is not a new problem. A hundred years ago we were polluting with mercury from steel mills, coal burning furnaces and other industries. At that time there were no environmental regulations. In fact, mercury pollution goes back 2,000 years to the smelting of silver. You should also know that attempts to test the mercury levels on fish preserved in museums in inaccurate since some of the preservation agents contain mercury. This taskforce appears clearly focused on the current problem and is looking for ways to remove an obvious health problem from the ecosystem. JCAA has always taken health advisories seriously. We represent anglers who eat the fish they catch. Since we have the greatest exposure through fish consumption, especially subsistence fishing, we need to know how this impacts on our families. This panel represents a wide range of interests and expertise. Governor Whitman and Commissioner Shinn should be congratulated for their commitment to this important issue.

RACHEL'S ENVIRONMENT & HEALTH WEEKLY #597 May 7, 1998        
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@rachel.org

A fight is shaping up over the amount of toxic mercury that the government will call "safe" in the human diet. The outcome of the fight will determine how strictly the government will control mercury emissions from incinerators, from coal-burning power plants, and from other industrial sources. The outcome will also directly affect the future of the commercial and recreational fishing industries. And of course it will affect the health of people --especially children --who eat mercury-contaminated food.

Mercury is an element, one of the 92 basic building blocks of everything on Earth. It is a silvery toxic metal that is liquid at room temperatures; many people know it as the silver liquid inside thermometers.

Humans ingest mercury mainly by eating fish. More than 95% of the mercury in fish takes the chemical form called methyl mercury, which is the most toxic form of the element. In 1996, U.S. EPA [Environmental Protection Agency] set a new guideline for methyl mercury in the diet: 0.1 micrograms of mercury per kilogram of body weight per day (0.1 ug/kg/day). This is 4.7 times as strict as the World Health Organization's (WHO's) standard of 0.47 ug/kg/day. EPA's science advisory board has approved EPA's guideline, which was established to protect children, including children who might be exposed in the womb. (The EPA's guideline is officially called a "reference dose" or RfD; it is the amount of methyl mercury that people are thought to be able to eat without any harmful effects.)

If the EPA's reference dose is taken seriously, it means that people should severely restrict their consumption of fish and shellfish. EPA recently published results of two surveys of mercury in freshwater fish, one completed in 1985 and one completed in 1994. The 1985 survey found an average of 0.11 parts per million [ppm] mercury in fresh water fish,[1,pg.4-71] and the 1994 survey found an average of 0.26 ppm mercury.[1,pg.4-73] Ocean fish have average mercury levels of 0.21 ppm.[1,pgs.4-66,4-67] Taken together, fresh water and marine fish have an average mercury concentration of about 0.2 ppm.

An average woman weighing 60 kilograms (132 pounds) can ingest 60 x 0.1 = 6 micrograms of mercury per day without exceeding the EPA reference dose. If each gram of fish contains 0.2 micrograms of mercury, our average woman could only eat 6/0.2 = 30 grams of fish per day without exceeding the EPA reference dose. There are 28 grams in an ounce, so roughly one ounce of fish per day (7 ounces per week) is the maximum amount that it is "safe" to eat, assuming that the fish is contaminated at the average level of 0.2 ppm mercury. Thus one good-sized serving of fish per week is about all that is safe, if the fish are contaminated at average levels.

EPA says that the fish species that people prefer to eat are contaminated at a level of only 0.12 to 0.14 ppm, for an average of 0.13 ppm.[2,pg.5-16] At this level of contamination, our average woman could safely eat 46 grams (1.6 ounces) of fish per day, or 322 grams (11.5 ounces) per week.

Of course some people prefer to eat species of fish that happen to accumulate large amounts of mercury: shark, swordfish, sea bass, walleye, and largemouth bass can contain 0.5 to 1.0 ppm or more.[2,pg.5-17] At these levels of contamination, consumption must be strictly limited to remain within EPA's guidelines. U.S. Food and Drug Administration (FDA) has set an "action level" of 1.0 ppm mercury for fish in interstate commerce but FDA has a very limited ability to measure how much mercury is actually in fish. If an "action level" is exceeded, FDA can issue a warning to consumers, but warnings are not posted where consumers might see them (for example, at fish markets); instead FDA warnings appear only in FDA publications. Furthermore, FDA's 1.0 ppm mercury limit was established to protect adults, not children.[3,pgs.35-46]

How much do Americans actually eat? EPA recently addressed this question. In 1990, there were 248.7 million Americans.[2,pg.5-29] Some 177 million were adults. Of these, 58% (or 102 million) eat fish once a week. Between 13% and 23% eat fish or shellfish 2 or 3 times a week. An estimated 1% (1.8 million people) eat fish or shellfish daily.[1,pg.4-19] Several populations eat more fish than average: people who fish commercially or for recreation tend to eat far more than average. Native people, people from the Caribbean, African-Americans, Asian-Americans, and Pacific-islanders tend to eat far more fish than average. Among these groups, some individuals eat 330 grams (12 ounces) of fish each day.

EPA believes that the critical population is women of childbearing age (15 to 44), of which there are 58.6 million in the U.S. Among women in this age group who report eating any fish at all, EPA estimates that half exceed the reference dose, 25% are ingesting twice the reference dose, 10% are ingesting four times the reference dose, and 5% are ingesting five times the reference dose.[2,pg.6-29]

Another critical population is young children. Mercury damages the nervous system, and the nervous system continues to develop through at least age 6. There are 15 million children in the U.S. between the ages of 3 and 6; EPA estimates that 20% of them (or 3 million children) exceed the reference dose for methyl mercury.[2,pg.6-32]

Fish is an important source of animal proteins and other nutrients.[4] At the fish store, fish is now expensive, but to subsistence fishers, it is often the only source of low-cost protein. Fish and shellfish are low in saturated fats, and they provide antioxidants such as selenium and vitamin E. They also offer beneficial omega-3 polyunsaturated fatty acids (PUFAs). PUFAs are important for optimal development of motor skills, the brain, and vision. Some, though not all, studies have shown that fish oils protect against heart attacks, and reduce blood pressure.

Based on the benefits that humans derive by eating fish, some authorities are urging that EPA relax its reference dose, to allow more methyl mercury into our diets.[4] For example, the Agency for Toxic Substances and Disease Registry (ATSDR) has proposed the the U.S. should adopt the World Health Organization's mercury standard of 0.47 ug/kg/day.[5]

An estimated 1600 to 4000 metric tons (3.5 to 8.8 million pounds) of mercury enters the atmosphere from natural sources each year.[6] Rain and snow then bring it down to Earth, where it ends up in streams and lakes, and ultimately the oceans. Humans roughly double this amount, contributing somewhere between 2000 and 6000 metric tons (4.4 to 13.2 million pounds) of mercury to the atmosphere each year.[7] The main human sources are solid waste incinerators, medical waste incinerators, hazardous waste incinerators, coal combustion, cement kilns, and the manufacture of chlorine using the chlor-alkali process.

The human contribution of mercury to the atmosphere is increasing at least 2% each year and in some countries the increases are even greater than that. So long as these increases continue, mercury will continue to accumulate in the bodies of fish.

As it is, 47 states in the U.S. have issued a total of 11,531 fish advisories for some or all of their waters during 1996, warning residents to limit their consumption of fish.[3,pgs.6-7] Of these warnings, 64% were for mercury.[3,pg.8] The mercury problem is serious now, and is getting steadily worse. Making the mercury health standard more permissive will take some of the pressure off of mercury-emitting industries and it will help the fishing business maintain its economic vitality, but it is a dubious public health proposition.

The EPA's reference dose, as strict as it seems to some people, was developed based on certain assumptions that are questionable. First, EPA based its estimates on the assumption that mercury has a half-life in the human body of 70 days.[2,pg.518] This is true, but the biological half-life of mercury in the brain is 230 days[8] --and the brain is the main organ that mercury attacks. (The biological half-life is the time it takes for the human body, or one of its organs, to rid itself of half of its burden of mercury.)

Second, EPA set its reference dose based on data derived from an acute poisoning incident in Iraq, not on the kind of chronic poisoning that produced so many mentally defective children near Minamata Bay in Japan. The mercury poisoning of some 10,000 people who lived around Minamata Bay during the period 1956 to 1974 showed that children can be poisoned by daily ingestion of fish polluted at only 0.11 ppm.[9]

And lastly, the EPA's reference dose was developed on the assumption that people who ingest mercury in fish are not also ingesting other toxicants. This is obviously a false assumption. A recent study by the Natural Resources Defense Council (NRDC)[3] shows unmistakably that fish in the U.S. are contaminated not only with mercury but also with numerous organochlorine compounds such as PCBs, DDT, chlordane, and dioxins. And of course lead is a constant threat to the health of American children, as it is in most other countries today.

Based on our own dismaying history of poisoning our children with lead and dioxins, we should be very cautious about declaring that we know what is a "safe" dose of mercury for anyone, especially for children growing in the womb.

--Peter Montague

(National Writers Union, UAW Local 1981/AFL-CIO)

===============

[2] Kathryn R. Mahaffey, Glenn E. Rice, and Rita Schoeny, MERCURY STUDY REPORT TO CONGRESS VOLUME VII: CHARACTERIZATION OF HUMAN HEALTH AND WILDLIFE RISKS FROM MERCURY EXPOSURE IN THE UNITED STATES [EPA-452/R-97-009] (Washington, D.C.: U.S. Environmental Protection Agency, December 1997). Available on the world wide web at: http://www.epa.gov/oar/mercury.html.

[3] Amy D. Kyle, CONTAMINATED CATCH; THE PUBLIC HEALTH THREAT FROM TOXICS IN FISH (New York: Natural Resources Defense Council, April, 1998). Available for $14 plus $3.00 shipping from: Natural Resources Defense Council, 40 West 20th Street, New York, NY 10011; telephone (212) 727-4486.

[4] Grace M. Egeland and John P. Middaugh, "Balancing Fish Consumption Benefits with Mercury Exposure," SCIENCE Vol. 278 (December 12, 1997), pgs. 1904-1905.

[6] William F. Fitzgerald and others, "The Case for Atmospheric Mercury Contamination in Remote Areas," ENVIRONMENTAL SCIENCE & TECHNOLOGY Vol. 32, No. 1 (January 1, 1998), pgs. 1-7.

[7] Carola Hanisch, "Where is Mercury Deposition Coming From?" ENVIRONMENTAL SCIENCE & TECHNOLOGY Vol. 32, No. 7 (April 1, 1998), pgs. 176A-179A.

[8] Masazumi Harada with Aileen Smith, "Minamata Disease: A Medical Report," in W. Eugene Smith and Aileen M. Smith, editors, MINAMATA (New York: Holt, Rinehart and Winston, 1975), pgs. 180-192.

[9] Tomohiro Kawaguchi, [Letter to the editor], SCIENCE Vol. 279 (January 23, 1998), pg. 460. And see Masazumi Harada, "Minamata Disease: Methylmercury Poisoning in Japan Caused by Environmental Pollution," CRITICAL REVIEWS IN TOXICOLOGY Vol. 25, No. 1 (1995), pgs. 1-24. And: Bernard Weiss, "Long Ago and far Away: A

Retrospective on the Implications of Minamata," NEUROTOXICOLOGY Vol. 17, No. 1 (1996), pgs. 257-264. And: Tadashi Ninomiya and others, "Expansion of Methylmercury Poisoning outside of Minamata: An Epidemiological Study on Chronic Methylmercury Poisoning outside of Minamata," ENVIRONMENTAL RESEARCH Vol. 70 (1995), pgs. 47-50.

Fishers today are capturing species that are significantly lower on the marine food chain than species they caught just 10 years ago, according to a recent study in the journal Science.

Since the early 1970s, marine fish stocks have been in a global free fall: Dozens of species have been fished to commercial extinction, the rate of growth in marine harvests has plummeted to nearly zero, and the composition of global catches has downshifted to smaller, bonier, oily fish that eat low on the food chain.

Although global harvests have increased dramatically since 1950, the average trophic level (the position within the marine food chain) of that harvest has dropped 10 percent, from 3.4 to 3.1, signaling a loss of complexity and biodiversity. These trends indicate a pattern of resource exhaustion. The study, co-authored by fisheries scientists from the University of British Columbia and the International Center for Living Aquatic Resources Management in the Philippines, is based on reports from around the world, including the United Nations Food and Agriculture Organization’s annual global catch data for 220 fish and aquatic species.

From these, the authors determined the average trophic level of each fish species— based on what the fish eat and what their prey eat—and then calculated the average trophic level of annual world harvests from 1950 to 1994.

This study marks one of the first attempts to designate fractional trophic levels for every commercial fish species, based on its interaction within the marine food web, rather than a whole-number designation, which ignores the fact that many fish feed at different levels. A high-trophic fish, such as tuna (4.2) or cod (3.8), for example, eats many smaller fish, such as herring (2.8) or pout (3.1) -- which in turn eat tiny fish, zooplankton and phytoplankton (2.2 to 2.5). Most of the fish consumed by people occupy levels 2.4 through 4.

As fishers deplete large, long-lived predatory species, such as cod, tuna, shark and snapper, they move down to the next level—to species that tend to be smaller, shorter-lived and less valuable. As a result, fishers worldwide now fill their nets with plankton-eating species, such as squid, jacks, mackerel and sardines, and invertebrates like oysters, mussels and shrimp. The new findings support the conclusion that fishers are working harder to capture less valuable species—they are essentially fishing down the food chain.

Initially, this transition brings new bounty: At higher trophic levels, fish are larger, but there are fewer of them. At lower levels, the species are smaller but more plentiful. In addition, higher-trophic species exert a top-down control on lower-trophic species. Relieved of predatory pressures and competition for food, the smaller species are free to fill in the empty niche once occupied by their predators. This is one reason why global fish catches have not declined dramatically in the past 25 years, despite severe overfishing.

When fishers deplete large predators, in a sense they select for smaller species, be they juvenile predators or altogether different species. But unless fishing effort is reduced, the cycle of overfishing will soon repeat itself, triggering abrupt declines in these lower-level species. Fishers may soon be only a step away from harvesting jellyfish, krill and plytoplankton.

The track record from the heavily exploited northern Atlantic and Pacific oceans, and the Mediterranean and Black seas, foreshadows the fate of other fishing grounds: The catch composition of each of these regions peaked by the early 1970s and has dropped steadily since then. Fisheries off the New England coast and Atlantic Canada have suffered a double blow—a 20 percent loss of trophic level and a 120 percent decline in total landings. Where fish of high trophic levels remain relatively abundant, as has Alaskan pollock (3.8 trophic level) in the Bering Sea and Gulf of Alaska, its influence on catch composition is outweighed by the over-exploitation of numerous other species, which causes a downward drag on the marine food web.

In contrast, the trophic level of catches in the eastern Pacific has fluctuated widely, reflecting the high variability of small species, such as anchovies, mackerel and sardines. In the southern Atlantic, trophic levels have increased slightly, most likely due to the exploitation of previously untapped stocks of squid and hake on the Patagonian shelf. Indeed, species that were once considered too expensive to harvest and unappealing to consumer tastes are now landed as a matter of course.

Redirecting fishing efforts to lower trophic levels can shift the populations of predator and prey alike. In the North Sea, for example, fishing for Norway pout benefited its prey, krill—but at the expense of copepods, a low-level zooplankton eaten by krill, pout and commercially valuable cod and saithe. Cod also consumes pout directly, so by targeting pout and indirectly harming copepods, fishers threaten the recovery of the cod and saithe fishery. As this example shows, once the slide to a lesser-quality fish begins, enabling the fishery to regain a higher trophic level is difficult, if not impossible.

An aspect of overfishing the study does not quantify directly is the subsequent loss of individual species’ roles in the ecosystem, which can have deleterious effects on nutrient flows and energy balance in the marine food web as a whole. Similarly, questions remain as to the degree to which these changes are reversible, how changes in population structure affect the overall productivity of the marine ecosystem and whether severe overfishing of lower-level species threatens to undermine the ability of all fisheries to recover.

The authors caution that continuing down the current path will lead to more fisheries collapses, lower trophic-level species and ultimately lower catches. But the cycle of fishing down the marine food web can’t go on forever. (At lower trophic levels, the species are so small and diluted that it is no longer economically feasible to fish.) At the current rate of descent, it will take only 30 to 40 years to fish down to the level of plankton.

The authors point to the strong leverage policymakers have with no-take marine reserves. Setting aside strategically located areas where fishing is prohibited can help rebuild fish populations and restore the marine ecosystem. But until fisheries are managed as an interactive ecosystem comprising dynamic and fluctuating multiple species, rather than a series of single species managed for optimum yield, any recovery in fish populations will be fleeting at best.

Copyright 1998, The Worldwatch Institute.

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