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Pacific

Clupea pallasii

©Scandinavian Yearbook / www.scandfish.com

California Bottom gillnet

August 21, 2014

Megsie Siple, Consulting researcher

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About Watch®

The Monterey Bay Seafood Watch® program evaluates the ecological sustainability of wild-caught and farmed seafood commonly found in the North American marketplace. Seafood Watch defines sustainable seafood as originating from sources, whether wild-caught or farmed, which can maintain or increase production in the long-term without jeopardizing the structure or function of affected ecosystems. The program’s mission is to engage and empower consumers and businesses to purchase environmentally responsible seafood fished or farmed in ways that minimize their impact on the environment or are in a credible improvement project with the same goal.

Each sustainability recommendation is supported by a seafood report. Each report synthesizes and analyzes the most current ecological, and ecosystem science on a , then evaluates this information against the program’s sustainability criteria to arrive at a recommendation of “Best Choice,” “Good Alternative,” or “Avoid.” In producing the seafood reports, Seafood Watch utilizes research published in academic, peer-reviewed journals whenever possible. Other sources of information include government technical publications, management plans and supporting documents, and other scientific reviews of ecological sustainability. Seafood Watch research analysts also communicate with ecologists, fisheries and scientists, and members of and conservation organizations when evaluating fisheries and aquaculture practices. Capture fisheries and aquaculture practices are highly dynamic; as the scientific information on each species changes, Seafood Watch’s sustainability recommendations and the underlying seafood reports will be updated to reflect these changes. Both the detailed evaluation methodology and the scientific reports, are available on seafoodwatch.org.

For more information about Seafood Watch and seafood reports, please contact the Seafood Watch program at Monterey Bay Aquarium by calling 1-877-229-9990 or visit online at seafoodwatch.org.

Disclaimer Seafood Watch® strives to ensure all its seafood reports and the recommendations contained therein are accurate and reflect the most up-to-date evidence available at time of publication. All our reports are peer reviewed for accuracy and completeness by external scientists with expertise in ecology, or aquaculture. Scientific review, however, does not constitute an endorsement of the Seafood Watch program or its recommendations on the part of the reviewing scientists. Seafood Watch is solely responsible for the conclusions reached in this report. The program welcomes additional or updated data that can be used for the next revision. Seafood Watch and seafood reports are made possible through a grant from the David and Lucile Packard Foundation.

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Guiding Principles

Seafood Watch® defines sustainable seafood as originating from sources, whether fished1 or farmed, that can maintain or increase production in the long-term without jeopardizing the structure or function of affected ecosystems.

The following guiding principles illustrate the qualities that capture fisheries must possess to be considered sustainable by the Seafood Watch program:

• Stocks are healthy and abundant. • Fishing mortality does not threaten populations or impede the ecological role of any marine life. • The fishery minimizes bycatch. • The fishery is managed to sustain long-term productivity of all impacted species. • The fishery is conducted such that impacts on the seafloor are minimized and the ecological and functional roles of seafloor habitats are maintained. • Fishing activities should not seriously reduce ecosystem services provided by any fished species or result in harmful changes such as trophic cascades, phase shifts, or reduction of genetic diversity.

Based on these guiding principles, Seafood Watch has developed a set of four sustainability criteria to evaluate capture fisheries for the purpose of developing a seafood recommendation for consumers and businesses. These criteria are:

1. Impacts on the species under assessment 2. Impacts on other species 3. Effectiveness of management 4. Habitat and ecosystem impacts

Each criterion includes: • Factors to evaluate and score • Evaluation guidelines to synthesize these factors and to produce a numerical score • A resulting numerical score and rating for that criterion

Once a score and rating has been assigned to each criterion, an overall seafood recommendation is developed on additional evaluation guidelines. Criteria ratings and the overall recommendation are color-coded to correspond to the categories on the Seafood Watch pocket guide:

1 “” is used throughout this document to refer to finfish, shellfish and other invertebrates. 4

Best Choice/Green: Are well managed and caught or farmed in ways that cause little harm to habitats or other wildlife.

Good Alternative/Yellow: Buy, but be aware there are concerns with how they’re caught or farmed.

Avoid/Red: Take a pass on these for now. These items are overfished or caught or farmed in ways that harm other marine life or the environment.

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Summary ( pallasii) is a pelagic schooling fish distributed around the North Pacific, from South Korea to Southern . The majority of Pacific herring catches occur in , Canada, and California. Commercial Pacific herring fisheries consist of three types: fresh fish (in which whole fish are sold for human consumption), sac (in which females are harvested and roe is sold) and roe on kelp (in which kelp is placed in spawning grounds, herring lay on it, and the kelp and eggs are sold). There are active commercial fisheries in Alaska and California in the U.S. These are predominantly sac roe and bait fisheries. This report will focus on herring (whole fish and sac roe) caught in the gillnet fishery in , California. It excludes the roe on kelp fishery because the “catch” is exported.

The for the San Francisco Bay herring fishery is still in development, so abundance estimates are not used to set annual harvest limits. Instead, the quota is revised each year based on annual adult biomass estimates from scientific surveys and landings data. Biomass has increased since a record low in 2008 to a level around the average over the last 45 years, and strong recruitment to fish of spawning age suggests that spawning stock biomass is likely to increase further. Landings have remained at or under the quota for sac roe and roe on kelp fisheries since 1987. Harvest is limited to 5% of the spawning biomass, and the fishery has been closed in years when abundance is too low.

The San Francisco Bay herring fishery has little bycatch, due to selective fishing gear and low nearshore salinities during the season. Bycatch species are limited to jack (Atherinopsis californiensis) and Pacific (Sardinops sagax). Jack smelt, which sometimes enter spawning grounds to feed on herring eggs after a spawning event, can often be avoided by fishermen with fathometers because of the species’ distinct acoustic signal. Other species found in catches include bullhead, shiner perch, English , and rock . These are not considered species of concern, and bycatch rates are likely <1%, so these species are not assessed here.

The fishery is managed by the State of California through the Department of Fish and Wildlife (CDFW) and the Fish and Game Commission (FGC). Major elements of the management regime are limited entry permitting, seasonal closures, annual biomass surveys, a precautionary limit on the amount of biomass that can be landed (5%), and mesh size restrictions (though these may not be perfectly eliminating the bycatch of underage herring). A Fishery Management Plan is under development that managers hope will include measures that allow for the determination of unfished biomass and reference points, a model that allows for a harvest control rule, and accounting for herring’s importance as prey for a great many predators.

The herring fishery in San Francisco Bay exclusively uses gillnets that are weighted on the bottom. These could potentially impact benthic and seagrasses. The current management plan does not include rules for mitigating gear impacts. But the fishery occurs mainly in areas with mud bottoms, and the short season and small spatial extent of the fishery make it unlikely that gear greatly affects the substrate. More data on gillnet placement relative to the distribution of seagrasses and algae in San Francisco Bay 6

are necessary to assess the habitat impacts of this fishery. Pacific herring are considered , which are defined by their functional role. Forage fish play an important role in energy transfer between and and upper trophic levels. Changes in forage fish biomass could cause declines in predators of forage fish, including commercially valuable species. Ecosystem model simulations have confirmed that this is also a concern in the California Current ecosystem where this fishery occurs. The precautionary harvest rate (5% of biomass) is lower than the level scientists have recommended to maintain the population in an optimal state for fishing (10%–15%)—specifically to provide for the species’ importance in the ecosystem. But it is unknown whether the harvest level is appropriate in an ecosystem context.

Pacific herring (while fish and sac roe) from California is considered a Best Choice.

Table of Conservation Concerns and Overall Recommendations

Stock / Fishery Impacts on Impacts on Management Habitat and Overall the Stock other Spp. Ecosystem Recommendation Pacific herring Green (4.47) Green (5.00) Yellow (3.00) Green (3.24) Best Choice (3.840) California Pacific - Gillnet, Bottom

Scoring Guide

Scores range from zero to five where zero indicates very poor performance and five indicates the fishing operations have no significant impact.

Final Score = geometric mean of the four Scores (Criterion 1, Criterion 2, Criterion 3, Criterion 4).

• Best Choice/Green = Final Score >3.2, and no Red Criteria, and no Critical scores

• Good Alternative/Yellow = Final score >2.2, and neither Harvest Strategy (Factor 3.1) nor Bycatch Management Strategy (Factor 3.2) are Very High Concern,2 and no more than one Red Criterion, and no Critical scores, and does not meet the criteria for Best Choice (above)

• Avoid/Red = Final Score <=2.2, or either Harvest Strategy (Factor 3.1) or Bycatch Management Strategy (Factor 3.2) is Very High Concern,2 or two or more Red Criteria, or one or more Critical scores.

2 Because effective management is an essential component of sustainable fisheries, Seafood Watch issues an Avoid recommendation for any fishery scored as a Very High Concern for either factor under Management (Criterion 3). 7

Table of Contents

About Seafood Watch® ...... 2

Guiding Principles ...... 3

Summary ...... 5

Introduction ...... 8 Criterion 1: Stock for which you want a recommendation ...... 17 Criterion 2: Impacts on Other Species ...... 22 Criterion 3: Management effectiveness ...... 24 Criterion 4: Impacts on the habitat and ecosystem...... 31

Acknowledgements ...... 35

References ...... 36

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Introduction Scope of the analysis and ensuing recommendation

Pacific herring (Clupea pallasii) is a pelagic schooling fish with stocks distributed around the Pacific Rim from Southern California to Korea. This report focuses on the major sources of wild captured herring for food, bait, and roe in the U.S. Pacific. The majority of herring fished in the U.S. comes from Alaska (with <5% of total domestic landings occurring in California and Washington), but this catch is nearly all exported. This assessment focuses on the herring fishery in San Francisco Bay, the only herring fishery in California that still has some commercial harvest. Because less than 0.5% of the landings from the roe on kelp fishery are sold in U.S. markets, only the sac roe and whole fish fisheries are analyzed here. The major gear type analyzed here is the bottom gillnet.

Overview of the species and management bodies

Pacific herring is a coastal, schooling forage fish species distributed throughout the northern Pacific from northern Baja California, Mexico, to Korea. Pacific herring typically spend spring and summer foraging in the , and aggregate in nearshore areas during fall and winter, after which they in the shallow subtidal. After spawning, adults recoup some energy loss by feeding at spawning grounds, and then return to . It is a relatively short-lived species; although it has a maximum reported age of 19 years, most individuals are no more than 6 years old (Morrow 1980). Each female lays between 40,000 and 50,000 eggs in one spawning season, and herring are repeat spawners. They can grow to a maximum size of 46 cm.

Pacific herring are considered forage fish, which are defined by their important functional role in marine ecosystems. Forage fish transfer energy from phytoplankton and zooplankton to higher predators. Pacific herring is a dominant forage species in the northeast Pacific, along with Pacific sardine, Pacific herring, Northern , Pacific , smelts, sand lance, market , and . Pacific herring eggs are preferred by ducks (Anderson et al. 2009) and (Bishop & Green 2001), and adult herring are consumed by a broad range of seabirds (Furness 2007), marine mammals (Weise & Harvey 2008), and piscivorous fish (Duffy et al. 2010) (Logan et al. 2011). In an analysis of prevalence in the diet of 121 predators in the California Current Large Marine Ecosystem (CCLME), Pacific herring is the fifth most important prey item across all taxa, and the second most important for seabirds (Thayer et al., in prep). In a separate analysis of occurrence in the diet of 32 predators in the CCLME, Pacific herring is the fourth most important prey item (Ainley et al. 2014).

Pacific herring also support a valuable commercial fishery in the U.S. Roe from fecund females (“sac roe”), eggs laid on kelp (sometimes referred to as “herring eggs on kelp”; referred to here as “roe on kelp”), and whole fish are all harvested in the U.S. The sac roe product is obtained by catching fecund females. The eggs are stuck together in an oblong shape called a skein, which is extracted from the females either on the boat or on shore. Skeins are packed in brine, and often soaked in freshwater before they are consumed. The roe on kelp fishery involves the removal of giant kelp (Macrocystis pyifera) from the subtidal, sometimes from different sites than where the herring spawn. The kelp is 9

then suspended in areas where herring spawn, and left in the water until the spawn has reached a certain thickness, at which point the kelp is harvested and dried or fried. Unlike the sac roe fishery, the roe on kelp fishery does not harvest any adults—only the eggs from the kelp.

Production Statistics

Mean annual catches of Pacific herring in California herring fisheries have been 1,737 t, and 1,412 t of Pacific herring were caught in California in 2012 (Figure 1). The majority of this is caught in the sac roe fishery, which consists of two platoons of boats that fish at different times using bottom gillnets.

The commercial sac roe fishery in San Francisco Bay caught 2,115 t of fish in 2012 and the roe on kelp fishery caught 35.6 t (the reported weight includes the weight of the kelp (Bartling et al. 2013)). The market for fresh fish has recently grown, and currently fresh fish and herring roe are allowed under the same permit. The quota for fresh fish is currently set at 20 t (daily market orders are less than 500 lb). The Department of Fish and Wildlife (CDFW) monitors landings and suggests an annual quota to the California Fish and Game Commission (FGC).

Figure 1. Quotas and landings for the sac roe and roe on kelp fisheries (in blue and green, respectively). Until 1989, quota and landings data for sac roe and roe on kelp fisheries were reported together. Data are from CDFW.

In 2012, Pacific herring accounted for 12.8% of the total global herring landings (FAO 2014). Since 1950, Pacific herring has made up 2% to 16% of annual global herring catches. Global Pacific herring landings peaked at about 506,000 metric tons (t) in 1998, with a long-term mean annual catch of ≈250,000 ± 13,000 t. Landings were dominated by Asian and American fisheries through the 1970s, and the current global catch of Pacific herring is mostly by European fishing fleets ((FAO 2014); Figure 1). Pacific herring is most frequently caught with purse seines and gillnets. It is also captured with hand lines and cast nets in the small bait fishery (not assessed in this report). All the catches in California in 2012 were made using bottom set gillnets, according to CDFW (these are recorded as “non-trawl nets” by the National Marine Fisheries Service (NMFS 2014)). The majority of catches occurred in San Francisco Bay, which is 10

restricted to gillnets, so non-trawl net catches recorded by NMFS are all from gillnets. The roe on kelp fishery in San Francisco Bay uses giant kelp harvested from the Central Coast of California.

Figure 2: Global landings of Pacific herring and U.S. imports of all herring species since 1975. (A) Annual global catches, from the National Marine Fisheries Service. Landings by European vessels have replaced catches by countries from Asia and the Americas in the last 30 years. (B) U.S. imports of Pacific herring products from each country; larger points represent a higher volume of imports. Data are from FAO.

Herring along the West Coast vary widely in population size, fishing pressure, and environmental stressors, and each state with Pacific herring populations monitors and manages their stocks separately. Some spawning populations of Pacific herring on the U.S. West Coast have been depleted or are populations of concern. The Sierra Club recently petitioned to list the Lynn Canal, Alaska Distinct Population Segment (DPS) as threatened or Endangered under the Endangered Species Act (ESA). Though the stock was classified as not warranting a listing (based on the lack of support for Lynn Canal and Juneau to be listed as a DPS), the fishery in Lynn Canal and Juneau has been closed since 1982. The Prince William Sound stock remains below its regulatory threshold (22,000 t) and the fishery has been 11

closed since 1999. Fisheries in Washington and Oregon are bait fisheries only, with small catches relative to those in California and Alaska (Stick & Lindquist 2009). In 2012, 95% of the Pacific herring catch in the U.S. came from Alaska, and 4% came from California (Figure 2).

Figure 3: Catches of Pacific herring on the U.S. West Coast from 1950–2012. Data are from NMFS.

Historically, spawning areas in California included San Diego Bay, the San Luis River, Morro Bay, Elkhorn Slough, San Francisco Bay, Tomales Bay, Bodega Bay, the Russian River, the Noyo River, Shelter Cove, , and Crescent City Harbor, with the largest catches in San Francisco and Tomales Bays (Figure 3). Catch comes from gillnets (Figure 4). As of 2014, the San Francisco Bay fishery is the only remaining active fishery and has the largest spawning population; Tomales Bay fisheries have been inactive since 2007, Humboldt Bay since 2005, and Crescent City Harbor since 2002. The San Francisco Bay fishery consists of whole fish, sac roe, and roe on kelp fisheries. The largest annual landings come 12

from the sac roe fishery, with a small amount of the quota allocated to the roe on kelp and whole fish market fisheries.

Figure 4: Catches in California from 1972–1990. San Francisco Bay has historically been the largest of the CA fisheries. Data are from Spratt (1992).

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Figure 5: Catches by gear type in California since 1950. Data are from NMFS.

IMPORTANCE TO THE US/NORTH AMERICAN MARKET

Most of the herring (Pacific herring and other species) available in United States markets is from Canada (69% in 2012; Figure 6). Import data for herring is not species-specific, so it is unknown exactly how much of total herring imports consist of Pacific herring and how much are . On average, 10% of global landings are Pacific herring, and 76% are Atlantic herring (FAO 2014). 14

Figure 6: Contribution (%) by country to U.S. herring markets. This includes all species of herring. “Other countries” indicates countries that each contribute less than 1% of the total U.S. imports. Data are from FAO.

Commercial catches of Pacific herring in the U.S. average 31,062 ± 437 t per year (NMFS 2014). These are largely exported to other countries, especially Japan (Figure 7). In California, there is a market for fresh whole Pacific herring from San Francisco Bay that may expand in the future. The CDFW recently proposed an amendment to regulations that would allow take for the whole fish market during the sac roe season in San Francisco Bay (CDFW 2013). The new regulations took effect in the 2013–14 season.

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Figure 7: Exports of herring to countries outside the United States. Exports from West Coast cities are assumed to be Pacific herring, and most exports go to Japan. Data are from NMFS.

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Common and market names

The name “herring” is attributed to several species of herring, and the most common in U.S. markets is Atlantic herring. Pacific herring roe is sold as kazunoko and roe on kelp is sold as kazunoko kombu or komochi kombu.

Primary product forms

Pacific herring is available as whole fish, herring roe, and roe on kelp. Whole fish are often smoked, kippered, frozen, fresh, or salted.

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Assessment

This section assesses the sustainability of the fishery(ies) relative to the Seafood Watch Criteria for Fisheries, available at http://www.seafoodwatch.org.

Criterion 1: Stock for which you want a recommendation This criterion evaluates the impact of fishing mortality on the species, given its current abundance. The inherent vulnerability to fishing rating influences how abundance is scored, when abundance is unknown. The final Criterion 1 score is determined by taking the geometric mean of the abundance and fishing mortality scores. The Criterion 1 rating is determined as follows:

• Score >3.2 = Green or Low Concern • Score >2.2 and <=3.2 = Yellow or Moderate Concern • Score <=2.2 = Red or High Concern Rating is Critical if Factor 1.3 (Fishing Mortality) is Critical.

Criterion 1 Summary

PACIFIC HERRING Region / Method Inherent Stock Status Fishing Subscore Vulnerability Mortality California Pacific 2.00:Medium 4.00:Low 5.00:Very Low Green (4.472) Gillnet, Bottom Concern Concern

Criterion 1 Assessment

PACIFIC HERRING

Factor 1.1 - Inherent Vulnerability

Scoring Guidelines

• Low—The FishBase vulnerability score for species is 0-35, OR species exhibits life history characteristics that make it resilient to fishing, (e.g., early maturing ( • Medium—The FishBase vulnerability score for species is 36-55, OR species exhibits life history characteristics that make it neither particularly vulnerable nor resilient to fishing, (e.g., moderate age at sexual maturity (5-15 years), moderate maximum age (10-25 years), moderate maximum size, and middle of food chain). • High—The FishBase vulnerability score for species is 56-100, OR species exhibits life history characteristics that make is particularly vulnerable to fishing, (e.g., long-lived 18

(>25 years), late maturing (>15 years), low reproduction rate, large body size, and top- predator). Note: The FishBase vulnerability scores is an index of the inherent vulnerability of marine to fishing based on life history parameters: maximum length, age at first maturity, longevity, growth rate, natural mortality rate, fecundity, spatial behaviors (e.g., schooling, aggregating for breeding, or consistently returning to the same sites for feeding or reproduction) and geographic range.

California Pacific, Gillnet, Bottom

Medium

The FishBase vulnerability score for Pacific herring is 28 out of 100 (Cheung et al. 2005). This is considered to be low to moderate vulnerability to fishing. However, herring is also highly vulnerable to fishing mortality during low-productivity years, and susceptible to anthropogenic impacts on the nearshore environment, such as oil spills.

Rationale: Pacific herring is sexually mature between 2 and 4 years of age (about 20.9 cm, although this varies between spawning populations and across the Pacific (Hay et al. 2008) (Schweigert et al. 2002)). Although it matures quickly and has a high fecundity, herring undergoes large fluctuations in productivity, and can be more suspectible to when productivity is low (Pinsky et al. 2011).

Long-term chronic inputs of contaminants from industrial activities (e.g., persistent organic pollutants) and short-term acute stress with lasting ecosystem impacts (e.g., oil spills) can affect herring productivity. Exposure to oil from oil spills can have lethal and sublethal effects on Pacific herring embryos, causing malformations, genetic problems, deformities, and mortality (Carls et al. 1999) (Incardona et al. 2012). Harmful algal blooms, , and variation in prey availability can decrease herring productivity and increase vulnerability to high levels of fishing mortality.

Factor 1.2 - Stock Status

Scoring Guidelines

• 5 (Very Low Concern)—Strong evidence exists that the population is above target abundance level (e.g., biomass at maximum sustainable yield, BMSY) or near virgin biomass. • 4 (Low Concern)—Population may be below target abundance level, but it is considered not overfished • 3 (Moderate Concern) —Abundance level is unknown and the species has a low or medium inherent vulnerability to fishing. 19

• 2 (High Concern)—Population is overfished, depleted, or a species of concern, OR abundance is unknown and the species has a high inherent vulnerability to fishing. • 1 (Very High Concern)—Population is listed as threatened or endangered. California Pacific, Gillnet, Bottom

Low Concern

Currently the stock assessment for the San Francisco Pacific herring stock consists of spawning biomass estimates each year, which are used to set precautionary targets for harvest. Other reference points

(unfished biomass, B0; biomass needed to obtain maximum sustainable yield, BMSY; and fishing mortality needed to obtain MSY, FMSY) are not available, and neither is an estimate of unfished age distribution. CDFW recognizes the lack of an estimate of unfished biomass as a weakness for the fishery, and has recommended precautionary harvest rules based on spawning stock biomass.

Biomass has increased since 2008, and strong recruitment of 3- and 4-year-old fish in 2011–2012 indicates that the stock is rebounding from low abundance in 2008–2009. Although the fishery is not considered overfished (Bartling, CDFW, pers. comm. 2014), the stock assessment is still being developed (CDFW 2013) and the lack of reference points means a formal classification cannot be made. But the upward trend in biomass since 2008 and recent conservative annual quotas allow for a rating of “low concern.”

Rationale: Precautionary quotas are important for Pacific herring because the species undergoes dramatic fluctuations in abundance in response to biological and physical drivers. Pacific herring is vulnerable to climate variability (Bartling et al. 2013) (Reum et al. 2011), competition from juvenile salmonids and other forage species (Deriso et al. 2008), and disease (Marty et al. 2010). Herring recruitment can also be impacted by human activities: herring eggs and embryos can suffer developmental abnormalities and mortality if exposed to crude oil (Jeffries et al. 2013). In 2007, a bunker oil spill from a container resulted in subtidal cardiac toxicity for herring embryos in the subtidal zone, and tissue necrosis and mortality for herring embryos incubating in an adjacent shallow intertidal site (Incardona et al. 2012). The population may still be recovering from this event. In San Francisco Bay, herring is subject to biological and anthropogenic pressures, which could overwhelm even a well-managed stock.

These concerns are relevant to San Francisco Bay. The preservation of larger fish (ages 4+) to support the gillnet fishery is a continuing concern; the 1997–1998 El Niño event led to greatly reduced abundance estimates for fish aged 4 and older (ostensibly because of lower productivity). Less upwelling and lower productivity in 2008–2009 are likely the causes of a second precipitous drop in biomass (Bartling, CDFW, pers. comm. 2014). Stronger cohorts of fish may lead to stock recovery (Figure 5), but can also experience disproportionate fishing mortality because they make up a larger proportion of the stock (CCR Title 14 Sections 163-164 2011). 20

Figure 8: (A) Annual spawning biomass estimates (black line) are used to determine quotas (blue) for the sac roe and roe on kelp fisheries. (B) Age composition by biomass measured during research surveys by CDFW from 2007–2012 show strong recruitment to age 2 in 2009. (C) Quotas and landings for the sac roe and roe on kelp fisheries (in blue and green, respectively). Until 1989, quota and landings data for sac roe and roe on kelp fisheries were reported together. Data are from CDFW.

Factor 1.3 - Fishing Mortality

Scoring Guidelines

• 5 (Very Low Concern)—Highly likely that fishing mortality is below a sustainable level (e.g., below fishing mortality at maximum sustainable yield, FMSY), OR fishery does not target species and its contribution to the mortality of species is negligible (≤ 5% of a sustainable level of fishing mortality). • 3.67 (Low Concern)—Probable (>50%) chance that fishing mortality is at or below a sustainable level, but some uncertainty exists, OR fishery does not target species and does not adversely affect species, but its contribution to mortality is not negligible, OR fishing mortality is unknown, but the population is healthy and the species has a low susceptibility to the fishery (low chance of being caught). • 2.33 (Moderate Concern)—Fishing mortality is fluctuating around sustainable levels, OR fishing mortality is unknown and species has a moderate-high susceptibility to the fishery and, if species is depleted, reasonable management is in place. 21

• 1 (High Concern)—Overfishing is occurring, but management is in place to curtail overfishing, OR fishing mortality is unknown, species is depleted, and no management is in place. • 0 (Critical)—Overfishing is known to be occurring and no reasonable management is in place to curtail overfishing. California Pacific, Gillnet, Bottom

Very Low Concern

Annual quotas have been set at ≤5% of the total estimated spawning biomass since 2010, and have historically been <10% of total estimated spawning biomass. There is no official harvest control rule, but because the catch is limited to such a small proportion of the total estimated spawning biomass, Pacific herring are ranked as having very low concern for fishing mortality.

Rationale: The San Francisco Bay herring stock is managed to maintain a spawning stock biomass that is large enough to replenish itself (i.e., to prevent recruitment overfishing). The CDFW and California Sea Grant assembled a team of experts in forage fish ecology and stock assessment, who determined that a harvest rate of 10%–15% would be sustainable (CDFW 2013). Annual quotas have been set at ≤5% of the total spawning biomass estimate since 2010, and have been <10% of total estimated spawning biomass since 1979. Annual landings have consistently remained within the quota (see Figure 7). This quota is a precautionary harvest limit so that even during years when oceanographic conditions are suboptimal, the population can replenish itself (CDFW 2013). There is no harvest control rule for Pacific herring yet; this is one of the benefits of CDFW’s proposed fishery management plan (FMP). Because of the relatively small proportion of spawning stock biomass allowed for catch in this fishery, it is assumed that the fishery has a small impact on the population.

Fishing mortality and unexploited spawning biomass (B0) estimates should be obtained from a formal stock assessment. The Centre for the Environment, Fisheries and Aquaculture Science is currently developing one in collaboration with the CDFW.

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Criterion 2: Impacts on Other Species All main retained and bycatch species in the fishery are evaluated in the same way as the species under assessment were evaluated in Criterion 1. Seafood Watch® defines bycatch as all fisheries-related mortality or injury to species other than the retained catch. Examples include discards, endangered or threatened species catch, and ghost fishing. To determine the final Criterion 2 score, the score for the lowest scoring retained/bycatch species is multiplied by the discard rate score (ranges from 0-1), which evaluates the amount of non-retained catch (discards) and bait use relative to the retained catch. The Criterion 2 rating is determined as follows:

• Score >3.2=Green or Low Concern • Score >2.2 and <=3.2=Yellow or Moderate Concern • Score <=2.2=Red or High Concern Rating is Critical if Factor 2.3 (Fishing Mortality) is Critical.

Criterion 2 Summary

Only the lowest-scoring main species is/are listed in the table and text in this Criterion 2 section.

Pacific herring: California Pacific, Gillnet, Bottom

Subscore:: 5.000 Discard Rate: 1.00 C2 Rate: 5.000

Species Inherent Stock Status Fishing Subscore Vulnerability Mortality PACIFIC HERRING Medium 4.00: Low 5.00: Very 4.472 Concern Low Concern There are no data available on bycatch species currently caught in this fishery. However, managers indicate that the bycatch rate in this fishery is very low (<1%, according to a study by the CDFW in 1998). Bycatch consists primarily of jack smelt (Atherinopsis californiensis) and Pacific sardine (Sardinops sagax); other species such as bullhead, shiner perch, English sole, and rock crab have been caught.

Gillnet mesh size selects for 3- and 4-year-old fish, and gillnets are usually set in shallow water (≈20 ft) where herring are actively spawning. Because the season for the Pacific herring fishery (December or January to March) coincides with freshwater input from rainwater and snowmelt into San Francisco Bay, the salinity where the fishery occurs is too low for most other marine forage species. For this reason, the catch comprises small, freshwater-tolerant species, and these are overwhelmingly Pacific herring.

Because there are no vulnerable or protected species caught in the fishery, and bycatch rates are likely <1%, no species other than Pacific herring are included in this assessment. 23

Criterion 2 Assessment

Factor 2.4 - Discard Rate

California/Pacific, Gillnet, Bottom

<20%

There is no bait used for the gillnet fishery. Because bycatch rates are negligible for the sac roe and fresh fish fishery (<1%), it is safe to assume that the ratio of discards to total landings is less than 20%. More data on actual discard rates on vessels is necessary for this fishery.

Rationale:

Bycatch data are not currently recorded for the San Francisco Bay Pacific herring fishery. However, a study performed by the CDFG in 1998 shows that brown smoothhound (Mustelus sp.), spiny dogfish (Squalus acanthias), English sole (Parophrys vetulus), Pacific sanddab (Citharichthys sordidus), staghorn sculpin (Leptocottus armatus), smelt, shiner perch (Cymatogaster aggregata), and jack mackerel (Trachurus sp.) were caught as incidental catch in the gillnet fishery. Gillnets with a mesh size comparable to the size used in the commercial fishery were set to catch herring for research in 1982, 1983, and 1988. Incidental catch rates for these studies were 0.0016, 0.0049, and 0.0023, respectively (1998, CDFG).

Most of the other forage species probably don’t encounter herring gillnets because of their range and degree of salinity tolerance. For example, delta smelt are an endangered species but are found in fresh water (their upper salinity tolerance is 26.8 ppt; salinity data collected from NOAA buoys near the fresher of the herring spawning sites (Swanson et al. 2000)). The delta smelt range only extends to northern San Pablo Bay, not San Francisco Bay, so there is no reason to believe that they are caught incidentally in the herring fishery.

The incidental catch rate for fresh fish and sac roe fisheries are negligible and bycaught species are rarely discarded (Bartling, CDFW, pers. comm. 2014). It is highly likely that the ratio of discards to total landings is less than 20%.

Russia, Trawl, Bottom

<20%

Because no discard information is available for this fishery, this estimate is based on the FAO’s global weighted discard rate of 9.6% for demersal finfish trawl fisheries (Kelleher 2005).

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Criterion 3: Management effectiveness Management is separated into management of retained species (harvest strategy) and management of non-retained species (bycatch strategy).

The final score for this criterion is the geometric mean of the two scores. The Criterion 3 rating is determined as follows:

• Score >3.2=Green or Low Concern • Score >2.2 and <=3.2=Yellow or Moderate Concern • Score <=2.2 or either the Harvest Strategy (Factor 3.1) or Bycatch Management Strategy (Factor 3.2) is Very High Concern = Red or High Concern Rating is Critical if either or both of Harvest Strategy (Factor 3.1) and Bycatch Management Strategy (Factor 3.2) ratings are Critical.

Criterion 3 Summary

Region / Method Management Management Overall of of Recommendation Retained Non-Retained Species Species California Pacific 3.000 All Species Yellow(3.000) Gillnet, Bottom Retained

Factor 3.1: Harvest Strategy

Scoring Guidelines

Seven subfactors are evaluated: Management Strategy, Recovery of Species of Concern, Scientific Research/Monitoring, Following of Scientific Advice, Enforcement of Regulations, Management Track Record, and Inclusion of Stakeholders. Each is rated as ‘ineffective,’ ‘moderately effective,’ or ‘highly effective.’

• 5 (Very Low Concern)—Rated as ‘highly effective’ for all seven subfactors considered. • 4 (Low Concern)—Management Strategy and Recovery of Species of Concern rated ‘highly effective’ and all other subfactors rated at least ‘moderately effective.’ • 3 (Moderate Concern)—All subfactors rated at least ‘moderately effective.’ • 2 (High Concern)—At minimum, meets standards for ‘moderately effective’ for Management Strategy and Recovery of Species of Concern, but at least one other subfactor rated ‘ineffective.’ • 1 (Very High Concern)—Management exists, but Management Strategy and/or Recovery of Species of Concern rated ‘ineffective.’ 25

• 0 (Critical)—No management exists when there is a clear need for management (i.e., fishery catches threatened, endangered, or high concern species), OR there is a high level of Illegal, unregulated, and unreported fishing occurring.

Factor 3.1 Summary

Factor 3.1: Management of fishing impacts on retained species Region / Method Strategy Recovery Research Advice Enforce Track Inclusion California Pacific Moderately Highly Moderately Highly Highly Moderately Highly Gillnet, Bottom Effective Effective Effective Effective Effective Effective Effective

Subfactor 3.1.1 – Management Strategy and Implementation

Considerations: What type of management measures are in place? Are there appropriate management goals, and is there evidence that management goals are being met? To achieve a highly effective rating, there must be appropriate management goals, and evidence that the measures in place have been successful at maintaining/rebuilding species.

California Pacific, Gillnet, Bottom

Moderately Effective

The San Francisco Bay herring fishery is managed by the California Fish and Game Commission (FGC). Management follows the requirements of the California Environmental Quality Act (CEQA) guidelines. Each year, CDFW carries out a fishery-independent spawning biomass survey, as well as commercial fishery sampling to assess the spawning stock. Using the available data, CDFW recommends a seasonal quota to the FGC. The fishery sets precautionary harvest rules based on fishery-independent surveys, and responds annually to changes in biomass. Because the Pacific herring fishery management plan (which should eventually include the determination of reference points and ecosystem needs for herring as a forage fish) is still in development, this fishery is ranked “moderately effective.”

Rationale: There is strong evidence that the fishery is monitored and enforced effectively. The fishery is controlled via limited entry permitting, seasonal closures, gear restrictions, and the separation of the sac roe fisheries into two platoons that fish at different times. Sac roe permit holders are also allowed to trade in their sac roe permits or roe on kelp permits. Recently, regulations were changed such that sac roe and whole fish fisheries operate under the same quota and fishing season, in order to increase the availability of fresh fish for local markets. Gillnets have replaced other gear types phased out in the late 1990s, including round haul (purse seine and lampara nets (Spratt 1992)). The commercial gillnet fishery enforces gear restrictions that should select for herring that are 4 years old and older: the FGC requires standardized net sizes (2-inch mesh and ≈119 m long), which must be tended at all times (Bartling et al. 26

2013). However, 2- to 3-year-old fish are still caught in the fishery (they composed >70% of the commercial catch for sac roe in the 2010–2011 season; Figure 8) (CDFW 2013), so gear is not absolutely selective for individuals 4 years old and older.

Figure 9: Age composition of total annual commercial landings for the sac roe fishery between 1976–2013. Data are from CDFW.

Overall, the fishery maintains a harvest strategy that buffers for environmental uncertainty and responds annually to changes in fish spawning biomass. However, several factors are not addressed by current management. The CDFW has recognized the need for determining unfished biomass, developing 27

a harvest control rule, developing a simulation model for herring management, and accounting for herring as a forage species. To address these needs, the CDFW is developing a fishery management plan (FMP) for Pacific herring. The FMP is still in development and has not yet been implemented, so the ranking of this fishery as “moderately effective.”

Subfactor 3.1.2 – Recovery of Species of Concern

Considerations: When needed, are recovery strategies/management measures in place to rebuild overfished/threatened/ endangered species or to limit fishery’s impact on these species and what is their likelihood of success? To achieve a rating of Highly Effective, rebuilding strategies that have a high likelihood of success in an appropriate timeframe must be in place when needed, as well as measures to minimize mortality for any overfished/threatened/endangered species.

California Pacific, Gillnet, Bottom

Highly Effective

There are no overfished, depleted, endangered, or threatened species targeted or retained in the San Francisco Bay herring fishery.

Subfactor 3.1.3 – Scientific Research and Monitoring

Considerations: How much and what types of data are collected to evaluate the health of the population and the fishery’s impact on the species? To achieve a Highly Effective rating, population assessments must be conducted regularly and they must be robust enough to reliably determine the population status.

California Pacific, Gillnet, Bottom

Moderately Effective

The CDFW carries out annual surveys to determine biomass and to recommend a quota to the FGC. The surveys consist of spawn surveys, which are used in other herring fisheries to provide a reliable estimate of total spawning biomass. The FGC then sets the annual quota based on recommendations from the CDFW. Though management methods are based on the best scientific evidence, better documentation could improve management, and an age-structured stock assessment would give a better indication of total abundance than spawning surveys alone. For this reason, the stock is given a score of “moderately effective” for this category.

Rationale: 28

San Francisco Bay herring are monitored by the same methods used in other Pacific herring fisheries: egg surveys on spawning beaches give egg density counts, which are then converted to adult spawning biomass based on a constant fecundity. The CDFW also collects fishery-independent age composition data from surveys and fishery-dependent age composition data from commercial catches (CDFW 2013). Although these are considered in the assessment of the population, they are not incorporated in a stock assessment. These surveys are reliable for estimating biomass, but may not give a reliable indication of the stock’s abundance, because individual fecundity varies by body weight and spawning biomass estimates may not reliably capture total stock abundance.

Subfactor 3.1.4 – Management Record of Following Scientific Advice

Considerations: How often (always, sometimes, rarely) do managers of the fishery follow scientific recommendations/advice (e.g. do they set catch limits at recommended levels)? A Highly Effective rating is given if managers nearly always follow scientific advice.

California Pacific, Gillnet, Bottom

Highly Effective

The FGC sets quotas based on recommendations from CDFW scientists. So far, the FGC has not exceeded the quotas recommended by the CDFW. Additionally, the CDFW has followed scientific advice from outside the agency. In 2003, the CDFW and California Sea Grant assembled an expert review panel for the California herring fisheries, and the CDFW has adopted management strategies based on the suggestions of the panel.

Rationale: The CDFW, in collaboration with California Sea Grant, assembled an expert peer-review panel for the California herring fisheries in 2003, with the intent of resolving conflicts between spawning biomass estimates made from acoustic and spawn surveys. Panelists were also asked to provide management recommendations based on their findings. The panel found that spawn surveys were a good method for estimating spawning biomass. They also suggested that the target exploitation rate be lowered (to 10%– 15% of spawning biomass) and that the CDFW adopt a stronger policy of documentation (CA Sea Grant 2003). After the peer-review recommendation, the CDFW has continued to perform only spawn surveys and reduced the target exploitation rate to below 10%. Acoustic surveys were discontinued also because they consistently overestimated spawning stock biomass.

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Subfactor 3.1.5 – Enforcement of Management Regulations

Considerations: Do fishermen comply with regulations, and how is this monitored? To achieve a Highly Effective rating, there must be regular enforcement of regulations and verification of compliance.

California Pacific, Gillnet, Bottom

Highly Effective

There is no observer coverage for this fishery, but CDFW fishery managers are often present to monitor landings as the fishery occurs. CDFW enforcement staff are also present in the Bay during the fishing season to enforce adherence to fishing regulations and to monitor offloading. There is strong evidence that the fishery is enforced effectively.

Every vessel in the fishery is required to submit receipts for their daily catch. Landings have remained under the quota every year since 1978 (when the first landings data are available). Enforcement officials verify the receipts when catch is returned to the dock.

Subfactor 3.1.6 – Management Track Record

Considerations: Does management have a history of successfully maintaining populations at sustainable levels or a history of failing to maintain populations at sustainable levels? A Highly Effective rating is given if measures enacted by management have been shown to result in the long-term maintenance of species overtime.

California Pacific, Gillnet, Bottom

Moderately Effective

It is unclear whether the current management strategy will result in the long-term maintenance of ecosystem abundance and stock integrity. There are no recovery benchmarks and the stock was at a historic low point in 2008. However, the stock is currently rebuilding (Bartling et al. 2013), and management is responsive to environmental changes and interannual changes in population size and age structure. Because of the uncertainty around long term maintenance, the track record for this stock is ranked “moderately effective.”

Subfactor 3.1.7 – Stakeholder Inclusion

Considerations: Are stakeholders involved/included in the decision-making process? Stakeholders are individuals/groups/organizations that have an interest in the fishery or that 30 may be affected by the management of the fishery (e.g., fishermen, conservation groups, etc.). A Highly Effective rating is given if the management process is transparent and includes stakeholder input.

California Pacific, Gillnet, Bottom

Highly Effective

The CDFW holds an annual town hall meeting through the California Fish and Game Commission to discuss changes in regulations with stakeholders. The CDFW also holds public annual meetings with the Directors Herring Advisory Committee (DHAC) to share data and to collaborate to manage the commercial herring fishery. The FGC invites stakeholder input during scoping and drafts of Supplementary Environmental Documents each year, and conducts hearings to receive public input (CalOST 2014).

Bycatch Strategy

Factor 3.2: Management of fishing impacts on bycatch species Region / Method All Kept Critical Strategy Research Advice Enforce California Pacific Yes Gillnet, Bottom Because all species caught in the fishery are retained, SFW criteria 3.2.1–3.2.4 are not addressed.

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Criterion 4: Impacts on the habitat and ecosystem This Criterion assesses the impact of the fishery on seafloor habitats, and increases that base score if there are measures in place to mitigate any impacts. The fishery’s overall impact on the ecosystem and and the use of ecosystem-based fisheries management (EBFM) principles is also evaluated. Ecosystem Based Fisheries Management aims to consider the interconnections among species and all natural and human stressors on the environment.

The final score is the geometric mean of the impact of fishing gear on habitat score (plus the mitigation of gear impacts score) and the Ecosystem Based Fishery Management score. The Criterion 2 rating is determined as follows:

• Score >3.2=Green or Low Concern • Score >2.2 and <=3.2=Yellow or Moderate Concern • Score <=2.2=Red or High Concern Rating cannot be Critical for Criterion 4.

Criterion 4 Summary

Region / Method Gear Type and Mitigation of EBFM Overall Recomm. Substrate Gear Impacts California Pacific 3.00:Low 0.50:Moderate 3.00:Moderate Green (3.240) Gillnet, Bottom Concern Mitigation Concern

Justification of Ranking

Factor 4.1 – Impact of Fishing Gear on the Habitat/Substrate

Scoring Guidelines

• 5 (None)—Fishing gear does not contact the bottom • 4 (Very Low)—Vertical line gear • 3 (Low)—Gears that contacts the bottom, but is not dragged along the bottom (e.g. gillnet, bottom longline, trap) and is not fished on sensitive habitats. Bottom seine on resilient mud/sand habitats. Midwater trawl that is known to contact bottom occasionally ( • 2 (Moderate)—Bottom dragging gears (dredge, trawl) fished on resilient mud/sand habitats. Gillnet, trap, or bottom longline fished on sensitive boulder or coral reef habitat. Bottom seine except on mud/sand • 1 (High)—Hydraulic clam dredge. Dredge or trawl gear fished on moderately sensitive habitats (e.g., cobble or boulder) 32

• 0 (Very High)—Dredge or trawl fished on biogenic habitat, (e.g., deep-sea corals, eelgrass and maerl) Note: When multiple habitat types are commonly encountered, and/or the habitat classification is uncertain, the score will be based on the most sensitive, plausible habitat type.

California Pacific, Gillnet, Bottom

Low Concern

The sac roe fishery operates exclusively with gillnets set on the bottom. There is a slight possibility that weights attached to the nets might impact benthic species, especially macroalgae and seagrasses ( marina grows in some spawning habitats). But the gillnets used in this fishery are anchored to the bottom by a single weighted line, which is unlikely to pull up substrate or vegetation. Most of the herring spawn in San Francisco Bay occurs on a mud bottom, with few primary producers. Additionally, the scale of the fishery is small, so overall impact of the fishery on the benthic habitat is minimal.

Factor 4.2 – Mitigation of Gear Impacts

Scoring Guidelines

• +1 (Strong Mitigation)—Examples include large proportion of habitat protected from fishing (>50%) with gear, fishing intensity low/limited, gear specifically modified to reduce damage to seafloor and modifications shown to be effective at reducing damage, or an effective combination of ‘moderate’ mitigation measures. • +0.5 (Moderate Mitigation)—20% of habitat protected from fishing with gear or other measures in place to limit fishing effort, fishing intensity, and spatial footprint of damage caused from fishing. • +0.25 (Low Mitigation)—A few measures are in place (e.g., vulnerable habitats protected but other habitats not protected); there are some limits on fishing effort/intensity, but not actively being reduced. • 0 (No Mitigation)—No effective measures are in place to limit gear impacts on habitats. California Pacific, Gillnet, Bottom

Moderate Mitigation

Gear impacts on soft sediment habitats are likely to be minimal, but scientific evidence to support this is lacking. The roe on kelp fishery uses kelp pieces that are suspended above the sediment, so it does not impact the benthos. The sac roe fishery uses gillnets with nylon-coated weighted lines at the bottom, which will probably touch the substrate but not pull up additional material (J. Mellor, pers. comm.). Because of the limited spatial extent of the fishery and the short fishing season, the herring fishery is 33

classified as having “moderate mitigation.”

Factor 4.3 – Ecosystem-Based Fisheries Management

Scoring Guidelines

• 5 (Very Low Concern)—Substantial efforts have been made to protect species’ ecological roles and ensure fishing practices do not have negative ecological effects (e.g., large proportion of fishery area is protected with marine reserves, and abundance is maintained at sufficient levels to provide food to predators). • 4 (Low Concern)—Studies are underway to assess the ecological role of species and measures are in place to protect the ecological role of any species that plays an exceptionally large role in the ecosystem. Measures are in place to minimize potentially negative ecological effect if hatchery supplementation or fish aggregating devices (FADs) are used. • 3 (Moderate Concern)—Fishery does not catch species that play an exceptionally large role in the ecosystem, or if it does, studies are underway to determine how to protect the ecological role of these species, OR negative ecological effects from hatchery supplementation or FADs are possible and management is not place to mitigate these impacts. • 2 (High Concern)—Fishery catches species that play an exceptionally large role in the ecosystem and no efforts are being made to incorporate their ecological role into management. • 1 (Very High Concern)—Use of hatchery supplementation or fish aggregating devices (FADs) in the fishery is having serious negative ecological or genetic consequences, OR fishery has resulted in trophic cascades or other detrimental impacts to the food web. California Pacific, Gillnet, Bottom

Moderate Concern

The Pacific herring gillnet fishery selects for small pelagic species. Pacific herring is a species of exceptional importance according to Seafood Watch criteria because they are crucial in the transfer of energy between low trophic level and piscivorous seabirds, marine mammals, and piscivorous fish. The CDFW recommends conservative catch limits that maintain the stock and provide enough biomass for predators, so this fishery is ranked ”low concern.”

Rationale: In coastal upwelling systems worldwide, forage fish feed on phytoplankton and zooplankton and are essential conduits of energy transfer between lower and upper trophic levels (Cury et al. 2000) (Freon et al. 2005). They are an important food source for seabirds: declines in the abundance of forage fishes 34

such as sardine, anchovy, and herring can have cascading effects on higher trophic levels that feed on them (Cury et al. 2011). Forage fish are also important in the diets of marine mammals and , some of which are valuable fisheries.

San Francisco Bay is part of the California Current Large Marine Ecosystem (CCLME), a productive upwelling ecosystem in which forage fishes such as sardine, anchovy, and herring compose 10% of the total biomass. A recent analysis of the CCLME food web demonstrated that fishing forage species to 40% of unfished biomass would lead to a >20% reduction in the abundance of forage fish predators, including marine mammals, seabirds, and commercially important fish species such as Pacific (Oncorhynchus spp.) (Daly et al. 2009) (Kaplan et al. 2013). In an analysis of occurrence in the diet of 32 predators in the CCLME, Pacific herring is the fourth most important prey item (Ainley et al. 2014). In San Francisco Bay, herring and herring eggs support several species of fish, seabirds, and marine mammals (CDFW 2013).

The gillnet fishery for Pacific herring selects for small pelagics, so it should consider predator needs as well as the potential for the stock to rebuild itself. An expert review panel assembled in 2003 to assess the harvest guidelines for the fishery and recommended a harvest rate of 10%–15% of estimated spawning biomass for the annual quota (CA Sea Grant 2003). But this assessment did not account for ecosystem needs. The 10%–15% harvest rate was modified to a more precautionary 5%, with the intent of providing a buffer in less productive years and allowing enough biomass for predator requirements. Currently, at least 95% of the spawning biomass is left in the water each year. This amount is intended to include biomass needed to replenish the stock as well as biomass required by predators (CDFW 2013). Though the current proportion of spawning biomass allowed is set with ecosystem needs in mind, it has not been explicitly accounted for in a stock assessment. One of the objectives in the development of the FMP for Pacific herring is to account for the importance of herring as a forage species (CDFW 2013).

35

Acknowledgements Scientific review does not constitute an endorsement of the Seafood Watch® program, or its seafood recommendations, on the part of the reviewing scientists. Seafood Watch® is solely responsible for the conclusions reached in this report.

Seafood Watch® would like to thank Ryan Bartling of the California Department of Fish and Wildlife, John Mellor of the San Francisco Herring association, and Geoff Shester of Oceana for graciously reviewing this report for scientific accuracy. 36

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