The Sanctuary is mandated to approach resource protection from a broad, ecosystem based perspective. This requires consideration of a complex array of habitats, species, and interconnected processes and their relationship to human activities. Krill are a critical component of the marine ecosystem and fundamental to the trophic structure of the marine life within the Sanctuary. The two principal species of krill that exist within the MBNMS and throughout the California current are Euphausia pacifica and Thysanoessa spinifera. These species are preyed upon by almost all commercially important species within Sanctuary waters including salmon, rockfish, squid, sardine, mackerel and flatfish. Blue whales, humpbacks, and numerous seabirds including sooty shearwaters, marbled murrelets, and common murres are dependent on krill as forage. Reliable regional estimates of biomass and prey requirements do not exist. However, it has been estimated that krill makes up between 15 and 60 percent of the diet of commercially significant fish in ecosystems with comparable trophic structures. More...

Ecological Role:
The Sanctuary is mandated to approach resource protection from a broad, ecosystem based perspective. This requires consideration of a complex array of habitats, species, and interconnected processes and their relationship to human activities. Krill are a critical component of the marine ecosystem and fundamental to the trophic structure of the marine life within the Sanctuary. The two principal species of krill that exist within the MBNMS and throughout the California current are Euphausia pacifica and Thysanoessa spinifera. These species are preyed upon by almost all commercially important species within Sanctuary waters including salmon, rockfish, squid, sardine, mackerel and flatfish. Blue whales, humpbacks, and numerous seabirds including sooty shearwaters, marbled murrelets, and common murres are dependent on krill as forage. Reliable regional estimates of biomass and prey requirements do not exist. However, it has been estimated that krill makes up between 15 and 60 percent of the diet of commercially significant fish in ecosystems with comparable trophic structures.

Krill are currently not harvested within the Sanctuary, however the potential exists for this fishery to develop in the future due to an increasing need for aquaculture feed. A krill fishery could not only severely impact the integrity of the marine ecosystem but could adversely affect commercial and recreational fisheries of all kinds as most target species are directly or indirectly dependent on the resource. To address this issue, MBNMS will explore the potential for the future harvest of krill, outline the current regulatory framework, and recommend permanent restrictions in the Sanctuary.

Current State and Federal Management:
California is the first state to ban fishing for krill in state waters. The bill was introduced by Assemblywoman Virginia Strom-Martin, and was aimed at "protecting the marine food web by stopping any krill fishery before it could be started in the state." The Strom-Martin bill was requested by the Pacific Coast Federation of Fishermen's Associations (PCFFA) and conservation groups after a krill fishery was established last year off British Columbia. A commercial harvest of krill off the Canadian east coast has been implicated in the poor recovery of cod in the region; the BC krill fishery is the first off the Pacific coast. PCFFA and others were concerned that "fishing for this essential link in the food chain would prevent the recovery of highly valuable and threatened commercial fish." This bill prohibits the taking or landing of krill of the genus Thysanoessa or the genus Euphausia for commercial purposes until January 1, 2011. The bill would further provide that after January 1, 2011, this commercial taking or landing is prohibited unless permitted under regulations adopted by the commission. There has been no federal action considered prohibiting or limiting krill fishing in federal waters by the regional councils, NMFS, or Congress.

(top)

Description of Potential Fishery in MBNMS:
There are a number of problems associated with the krill industry. Krill have extremely powerful digestive enzymes that tend to spoil the catch by breaking down the krill's body tissue soon after death. Krill shells are also rich in fluoride so they have to be removed before the meat is fit for human consumption. These processing problems all add to the cost of production so that fisheries have failed to grow as fast as some had initially predicted. Of the global catch, 43% is used for aquaculture feed, 45% is for sport fishing bait, and 12% is for human consumption. The only significant market for krill on the west coast exists in Oregon and Washington were salmon farms use krill meat to give farm raised fish their pinkish color. Most of the supply comes from the British Columbia fishery. However, the federal waters in the sanctuary may soon be open to fish farming, outside the reach of state governments. NMFS is currently soliciting comments on their proposed Code of Conduct for Offshore Aquaculture, which could place net pens in areas of the Sanctuary. This code was generated pursuant to the Department of Commerce’s stated goal of a five hundred percent increase in the nation’s aquaculture by the year 2025. These net pen raised fish will likely demand krill as feed stock. This may further increase the likelihood of a krill fishery developing within Sanctuary waters.

A krill fishery within the MBNMS would correspond to peak krill abundance and aggregation which occurs in summer and early fall. Any trawling vessel could participate and as other fisheries are closed down there will be an increasing number of vessels searching for viable alternatives. However, there are several key limitations that would serve to effectively exclude most local fishermen from any emerging krill fishery. Perhaps most significantly the Strom-Martin bill not only prohibits the taking of krill from state waters but it also makes landing krill in any state port illegal. Therefore, a krill fishery on the central coast would most likely consist of either large out of state trawlers or an unlikely partnership between local vessels and out of state motherships or net pen aquaculture facilities. Whoever the primary participants may be, the biggest obstacle for a fishery within the MBNMS would be the krill’s dispersion and aggregation patterns. While harvestable krill swarms are to some extent spatially and temporally predictable, a significant percentage of these aggregations occur within state waters.

The Antarctic Example:
Estimates of krill abundance, based on the amount of krill freed up by the removal of the baleen whales from the Southern Ocean, suggested a sustainable krill harvest of around 150 million tons a year, 1.5 times greater than the total number of fish and shellfish harvested annually from the world's oceans. Commercial krill fishing began in the early 1970s and has continued unabated ever since. The current catch is a little under 300,000 tons a year which although down from the peak years of the early 1980s, is still by far the largest catch in Antarctic waters. Krill are caught by large freezer trawlers and processed on board into products for human consumption, domestic animals (cattle, poultry, pigs and mink) and farmed fish. Currently only six nations are actively involved in the fishery: South Korea, Chile, Poland, Japan, Russia and the Ukraine, with the last three accounting for 96 percent of the catch.
The prospect of a free-for-all fishery for Antarctic krill led to the signing of a unique fishing treaty in 1981. This is the Convention on the Conservation of Antarctic Marine Living Resources (CCAMLR), designed to protect the Antarctic ecosystem from the consequences of a rapidly expanding krill fishery. CCAMLR set a limit of 1.5 million tons on the catch of krill in the South Atlantic (where almost all of the krill has been caught recently) and a limit of 390,000 tons for the Indian Ocean. These limits are much higher than the current catch levels but this is a reflection of the huge size of the resource and of the pre-emptive approach to management that CCAMLR was designed to take. Market demand has been the limiting factor since the fishery began and catch has remained at a fraction of what are considered highly precautionary limits.

While the overall take of Antarctic krill is relatively low compared to its abundance, concerns have been raised over fishing’s regional effects. CCAMLR has instituted an ecosystem monitoring program to detect and record significant changes in critical components of the ecosystem. It has been assumed that it is possible to assess the effects of fishing on krill availability through some index of predator performance. Predator data has therefore been incorporated into the management scheme. Accordingly, a system to regularly record selected life history parameters of key seabird and seal populations has been in place since 1986. Despite calculations of krill yield that take into account krill and predator requirements, CCAMLR has been aware of the potential for local competition between predators and the krill fishery. On a global or regional scale fishing mortality might remain within the limits set by management and so provide sufficient escapement for predator needs. However, on a local level mortality may be much greater and escapement too low to support predators with restricted foraging ranges, or may cause a shift in the behavior and distribution of more widely ranging species. This concern is exacerbated by the timing of the krill fishery during months where many species of breeding bird and seal predators are dependent on the resource.

(top)

Issues of Concern for MBNMS:
The oceanographic and bathymetric features of the MBNMS makes it uniquely susceptible to the adverse effects of krill fishing. The Monterey submarine canyon provides krill with a distinctive habitat that contributes to their abundance and degree of aggregation. This makes the waters within the Sanctuary a critical feeding ground for countless forms of wildlife. These include predators like the blue whale, dense concentrations of seabirds, and commercially important fish species such as salmon and rockfish. The canyon habitat provides opportunity for high nighttime surface feeding due to its location downstream from an upwelling center, a refuge from daytime predation as krill can migrate to depths in excess of 100m in the canyon, and reduced swimming energy output during daytime schooling at depth due to reduced canyon slope currents.

As the fishery would correspond to the times of peak blue whale abundance it could be expected that the fishery could interfere with both the feeding behavior of the whales, the whale watching industry, and tourism in general. Bycatch is also a concern in that even though krill swarms are densely aggregated, a very fine mesh net is used which would indiscriminately catch larger predators. A krill fishery could adversely impact commercial and recreational fisheries of all kinds as all target species are directly or indirectly dependent on the resource. Particularly susceptible are recovering rockfish populations which would not only compete with a fishery for forage but would also be caught as bycatch.

Strategies to be Pursued in the Work Group:
The goal of the this working group is to identify and pursue strategies that result in a permanent ban on harvesting krill anywhere within the Sanctuary. The initial phase will focus on formulating an ecological report that includes a species-specific list of organisms dependent on krill within the MBNMS and an assessment of the potential for fishing within the MBNMS and its ecological and economic impacts. The next phase would involve approaching NMFS and CDFG with this information, with the objective of having these agencies enact a permanent ban on krill harvesting. If these agencies do not agree to establish such a prohibition, then the Sanctuary would request their endorsement of a Sanctuary enacted ban.

Statutory and Regulatory Context for Prohibiting Krill Harvesting:
The original Designation Document and Final EIS for the MBNMS state that existing fisheries are not being regulated as part of the initial MBNMS regime. However, the Final EIS also states that if regulatory exemptions for fishing threatens Sanctuary resources, NOAA could undertake rule changes consistent with Federal procedures. This would involve the MBNMS consulting with CDFG, PFMC, and NMFS to determine an appropriate course of action. The National Marine Sanctuary Program recognizes that the primary regulatory authority over fisheries management resides with these agencies, and as an initial step will encourage these agencies to take the necessary measures. However, their associated management strategies have generally been species specific approaches that are not always adequate to safeguard marine ecosystems. The National Marine Sanctuary Act focuses on protection of the ecosystem as a whole, a field in which the Sanctuary Program has 30 years experience. Pursuing the restriction of krill harvesting is therefore a legitimate means for the Sanctuary to both meet its mandate, and a valuable opportunity to provide its ecosystem based perspective to fisheries management.

Citations:
Nicol, S. & Endo, Y. Krill Fisheries: Development, Management and Ecosystem Implications. Aquat. Living Resour. 12 (2) (1999) 105-120.

(top)