Our Letter Concerning the Federal Review of Alewife and Blueback Herring
Re: Alewife and Blueback Herring Status Review NOAA–NMFS–2017–0094)
October 13, 2017
Tara Trinko Lake
NMFS, Greater Atlantic Regional Fisheries Office
55 Great Republic Drive
Gloucester, Massachusetts 01930.
Dear Ms. Lake,
Founded in 1898 the Connecticut Audubon Society is an independent organization that conserves Connecticut’s environment through science-based education and advocacy focused on the state’s bird populations and habitats. Osprey Nation is Connecticut Audubon Society’s citizen science partnership, launched in the summer of 2014, to monitor the health of our state’s Ospreys. The goal of Osprey Nation is to create a long-term record of data that will give the conservation community a better understanding of the health of Connecticut’s Osprey population.
Based on the first four years of data, as well as other information, we urge the NMFS to provide additional protection by listing both Blueback Herring and Alewife under the Endangered Species Act.
Through our four years of monitoring Ospreys along the coast of Long Island Sound we have anecdotally observed that adults returning to their nesting territories in March from Brazil are largely dependent upon the early spring runs of blueback herring (Alosa aestivalis) and alewives (Alosa pseudoharengus) for sustenance until large numbers of menhaden (Brevoortia tyrannus) arrive, about the time Osprey eggs begin to hatch.
According to the Birds of North America account for Osprey, “…in coastal southeastern Massachusetts, Ospreys eat primarily herring (Alosa sp.) before egg-laying and during incubation, when those anadromous fish migrate into fresh-water streams and ponds, then switch to a variety of marine fish (especially Atlantic menhaden [Brevoortia tyrannus]) during chick-rearing when Alosa move back to the sea (AFP).”
These early spring herring runs also coincide with the spring migration of Northern Gannets and Common Loons through the Sound. Their concentrated active feeding here is certainly focused on these herring runs, as the migration of other forage fish species in the Sound does not occur until later in the spring.
These migratory fish play an important role in the food web of Long Island Sound and are a major forage species for not only migratory water birds, but also predatory fish species such as striped bass (Morone saxatilis), bluefish (Pomatomus saltatrix) and also marine mammals once again repopulating Long Island Sound waters.
In addition to the important role these herring play in the ecology of Long Island Sound, they make up a critical link in the ocean food webs and have been documented as important prey species for Razorbill and Atlantic Puffin in both the breeding and non-breeding seasons. These species are recognized as globally near threatened and vulnerable on the IUCN Red List of threatened species, as maintained by BirdLife International.
Blueback herring have also been documented as a food source for the federally endangered Roseate Tern according to the Birds of North America Account. River herring serve many important ecological functions that must take precedence over their commercial value.
The important ecosystem role of these fish is not simply spread equally across the species range but is also a function of high abundance stages during periods when adults gather in mass to migrate upstream to spawn and again when young-of-the-year migrate downstream to the ocean. These river mouth and coastal aggregations provide dense food accumulations for many coastal birds such as Osprey and Common Loon (Connecticut special concern). These food patches reduce the energy needs of these and other water birds to search for prey and are clearly critical for fledging their young.
Our concern is that the commercial harvest of these species and habitat restrictions such as decreased access to spawning areas from the construction of dams and other impediments to migration and habitat degradation has led to dramatic declines in these river herring species. Both of these species, once abundantly observed in our streams and rivers are now noticeably absent throughout most of their traditional spawning areas in Connecticut.
We understand that Connecticut has not seen increases in river herring numbers despite all the conservation and restoration efforts our state, federal, municipal and private conservation partners have taken. We feel that it is irresponsible to manage these species with a one-size-fits-all approach.
The fact that Alewives seem to be doing well in Maine should not preclude more protective measures for Blueback Herring in Connecticut. Modern fisheries management should be managing by stocks or Distinct Population Segments, not by the full coast-wide population.
Both river herring species have been segregated into genetically identifiable stocks and the stocks to which Connecticut Alewife and Blueback Herring have been assigned are both doing poorly and should not be managed in the same manner as healthy stocks
We must take into consideration the overall ecological importance of these fish and the effect they have on the ecosystem as a whole. Continuing to adjust the commercial harvest of these species largely on the cost/ratio of economic feasibility is simply slicing the pie into smaller pieces and is short-sighted and damaging to our ecosystem.
Connecticut has spent millions of dollars restoring the natural flow and habitat connectivity of our rivers and constructing fish ladders in an effort to slow the decline of these anadromous species and help reverse their march to extinction.
The data collected by our state DEEP Fisheries Division demonstrates that the runs of these river herring species remain depressed relative to what they were prior to the mid-1980s and there have been no significant recovery of our local stocks. Traditional approaches to fisheries management as practiced by the Atlantic States Marine Fisheries Commission and the New England Fisheries Management Council have not been effective at protecting our local stocks and promoting the re-building of these stocks. Something more is needed.
In order to reverse this decline and begin to restore these important fish species, we urge the NMFS to provide additional protection by listing both Blueback Herring and Alewife under the Endangered Species Act.
Thank you for your consideration.
Patrick M. Comins