Forage Fish
Forage fish play an important role in sustaining the structure and productivity of marine ecosystems. While there is no universal definition of “forage fish,” they tend to be small, short-lived fish and invertebrate species that are subject to predation throughout their lifespan. Forage fish facilitate the transfer of energy to higher trophic levels by consuming very small prey and then being eaten by larger fish, marine mammals, and seabirds. Due to their short lifespans and sensitivity to environmental conditions, many forage species experience substantial fluctuations in recruitment and abundance. These factors pose challenges for traditional management approaches.
The required and discretionary provisions of the Magnuson-Stevens Act provide the Councils with broad authority to address forage concerns while allowing Councils the flexibility to develop regionally-appropriate management approaches. Details about Council-specific approaches may be found in the links at the bottom of the page.
CCC Consensus Position
In May 2022, the Council Coordination Committee (CCC) adopted the following consensus position on behalf of the eight regional fishery management Councils:
“The CCC recognizes that forage species play an important role in the structure and function of marine ecosystems. Under existing MSA provisions, some Councils have incorporated protection for forage species into FMPs where appropriate. The CCC believes the MSA already provides the Councils with adequate authority to address forage concerns. Current management efforts could be complicated by new requirements for forage fish management as it is not clear how these efforts would interface with the existing National Standards, which are the foundation of the MSA.
The CCC believes that forage fish cannot be defined with a one-size-fits-all description or criteria. Species identified as forage fish by the Councils tend to be small species with short lifespans and may have an important role in the marine ecosystem of the region. Some of these species may exhibit schooling behavior, highly variable stock sizes due to their short life spans, and sensitivity to environmental conditions. Some forage species may consume plankton, and some may be an important food source for marine mammals and seabirds.
The CCC is concerned that any legislative definition of forage fish based on broad criteria–such as all low trophic level fish (plankton consumers) that contribute to the diets of upper tropic levels–may not include other important types of forage species (e.g., squid) or unintentionally include important target fish species (e.g., pollock, shrimp, sockeye salmon, and whiting). Such broad definitions could allow for variable interpretations by different interested parties and thus invite litigation. The term "forage fish" appears to imply a special importance of the species as prey; however, nearly all fish species are prey to larger predators and thus all fish species provide energy transfer up the food chain. Further, the prey consumed by upper trophic predators are part of the natural mortality assumption in stock assessments.
The CCC believes that Councils should retain the authority to determine which species require conservation and management through FMPs. Any legislation that directs the Secretary to prepare or amend fishery management plans (e.g., recent legislation to add shad and river herring as managed species) creates conflicts with current management under other existing authorities. This can lead to confusion and additional litigation risk. Further, in order for a Council to add a forage fish to its FMP, there would need to be quantitative data to support federal management of that forage fish species.
Provisions that would require Councils to specify catch limits for forage fish species to account for the diet needs of marine mammals, birds, and other marine life would greatly impact the ability of Councils to fulfill their responsibilities under the MSA. Many predators are opportunistic feeders and shift their prey based on abundance and availability. As a result, determining the exact amount of individual prey needed each year would be an enormous undertaking, and would divert limited research funds away from other critical research such as monitoring surveys, processing of fishery-independent and dependent samples, and stock assessments. NOAA and the states do not currently have enough resources to survey target stocks, let alone prepare stock assessments for forage species that would be needed to set science-based annual catch limits. In the absence of this critical information, the Councils’ SSCs would have great difficulty addressing possible statutory requirements for forage fish. For example, information on the localized distribution of forage fish and ecological overlaps with other species and fisheries is often limited and highly variable. It is unlikely the necessary data and resources would be available in the near term, which could lead to more restrictive management measures for commercially valuable species that may fall under a definition of forage fish.”
See the MSA Working Paper available on this page for additional details and regional perspectives on forage fish management.
