Louisiana’s small but vital menhaden or “pogie” industry plays an oversized role in the economic well-being of several coastal parishes and in the financial security of more than 800 people who work directly in the industry, as well as several thousand more who benefit through indirect expenditures and investment.
Yet today, special interests with their narrow private agendas are asking the state legislature to place severe and unnecessary limitations on the last remaining menhaden fisheries — an action that would effectively shutter the industry and put thousands of coastal community residents out of work and into financial jeopardy.
Your voice, joined with residents and community leaders in Plaquemines, Jefferson, and Vermilion Parishes and beyond, can help make a real difference for many people whose very livelihoods and ways of life are being threatened by narrowly focused and deep pocketed special interests intent on closing down menhaden harvesting, processing and transportation companies.
Learn more about the menhaden industry in FAQs.
THE INDUSTRY
Menhaden have been a vital part of the state’s commercial fisheries for over 70 years. Today, menhaden are harvested for use as fertilizers, animal feed, and bait for other fisheries. A major source of omega-3 fatty acids, menhaden are also used to develop human and animal supplements.
Even before the modern era of menhaden fishing, Native Americans knew their value as an important fertilizer for their crops, a lesson they shared with others who began to move into the area.
While the size and scope of the industry’s footprint in southern Louisiana has decreased over the past several decades, one thing has not changed: The industry’s commitment to being a responsible corporate citizen working to bring meaningful value to the state and the local communities it serves, and to the millions of consumers around the world who depend on menhaden-based products to improve their health and quality of life.
Louisiana's menhaden industry has a sizable employment footprint in Plaquemines, south Jefferson and Vermilion parishes where safe, well paying and reliable jobs are hard to come by and harder still to sustain. Through jobs in fishing, processing, packaging and transportation, the industry is an important part of these local economies — providing safe work, good salaries, and benefits for area residents as well as much needed tax dollars for parish and local governments. Beneficiaries of these jobs include local retail outlets, restaurants, and more.
End Products
Menhaden, or “pogie” as they are sometimes called, are small, flat fish with an oily flesh that is silvery in color. They are filter feeders that travel in large, slow moving schools and are prey for larger fish and some birdlife. They have no value for human consumption unless processed and converted into other menhaden-based products.
Menhaden-based products are rich in Omega 3 which has numerous health benefits for consumers all over the world. Menhaden are processed into fish oil and fish meal for use as fertilizer, food ingredients, animal feed and as a dietary supplement. These products help lower blood pressure and reduce the chance of heart attack or stroke.
A March 2022, economic study funded by the Science Center for Marine Fisheries, National Science Foundation, shows that the Gulf menhaden fishery in Louisiana and Mississippi generates $419 million in yearly economic output while supporting 2,059 direct and indirect jobs. It also found that the industry generates around $25 million in state and local tax revenues.
These jobs, particularly in places oil and gas jobs have dried up (including from the spring 2022 closure of the Phillips 66 refinery in Belle Chasse), are especially important to local families and the small businesses that depend on generating their own revenues from residents’ spending. Shuttering or further restricting operations in the menhaden fishery will devastate the local economy and force the relocation of scores of families with few other opportunities for employment.
Altogether the industry has a direct, indirect and induced impact of $419.3 million annually according to Thomas J. Murrey and Associates in a report commissioned by the Science Centre for Marine Fisheries dated March 2022.
“Losing jobs in the pogie industry would cripple hundreds of families in places like Plaquemines Parish where new job creation is always tough.”
Mitch Jurisich, Chair, Louisiana Oyster Task Force and Plaquemines Parish Councilmember
While detractors would have you believe the industry lacks oversight, the facts prove otherwise. Louisiana’s menhaden industry is rigidly monitored or regulated by numerous federal and state agencies and departments including:
Together, these agencies ensure the highest standards of environmental excellence and the protection of the pogy resource. The industry is also closely monitored on a daily basis by independent monitors whose work is paid for through funding from the 2010 BP Deepwater Horizon oil spill recovery fund. Those who claim the industry isn’t well regulated are badly misinformed.
The industry’s track record of abiding by the letter and the spirit of relevant laws and regulations is exemplary and demonstrates the fact that the state’s menhaden fishing and processing companies can and do operate in harmony with other commercial and recreational fishing interests. Many in other related fields of commercial fishing such as the state’s shrimpers, crabbers, and oyster harvesters support the menhaden industry and recognize both its importance to the coastal communities and its commitment to operational and environmental excellence. The fact that these other fisheries sectors are in no way adverse to the menhaden industry speaks volumes.
Louisiana’s menhaden harvesting companies are deeply committed to ensuring that the menhaden stock is not overfished and that the species is protected for years to come. The 2021 stock assessment by the Gulf States Marine Fisheries Commission shows that Gulf menhaden “is not overfished or experiencing overfishing”. Studies dating back to 1977 when there were many more boats involved in harvesting menhaden also prove that fact. Moreover, in 2019 the menhaden fishery was certified “sustainable” by the Marine Stewardship Council, the only commercial fishery in the Gulf Coast to obtain this certification. This certification only came after more than two years of detailed review by an independent assessment body, extensive peer and stakeholder input and the final approval of an independent analyst. To be clear, the fishery was found to be sustainable, to have a minimal impact on the environment and to have an effective management system in place.
Further proof of the industry’s commitment to being a good corporate citizen and steward of the marine resources is the industry’s self-imposed commitment to fish only from mid April through October each year rather than on a year round basis. Doing so allows the stock of pogy to reproduce and replenish itself for almost five months of the year. The industry has also limited its fishing operations to the five week days, allowing recreational boaters and fishermen full access to Gulf waters on weekends. And, menhaden boats restrict their operations on major holidays such as Fourth of July or Labor Day as a courtesy to recreational interests even though there is no limitation on doing so.
Another example of the industry’s commitment to being a good neighbor in the Gulf is the self imposed limitation which prevents boats from operating within three miles of Grand Isle. All told, no other stakeholders in the Gulf have placed more voluntary restrictions on themselves that the menhaden fishery.
While it may be convenient for opponents of the industry to make allegations regarding Louisiana’s menhaden fishery companies, backing those allegations up with facts is a much steeper climb. In point of fact, independent study after study show that the industry abides by all relevant state and federal laws and regulations to protect the marine resources to the benefit of all who share Gulf waters.
Demands for even more regulation by some with their own self serving agendas have no merit, a fact demonstrated as recently as 2021 through a study published in Conservation Biology that concluded that adopting extra-precautionary catch limits on forage species like menhaden is unlikely to result in higher predator populations. A similar 2017 study published in Fisheries Research, found that increases in predator populations were not correlated with increases in forage abundance, that forage species are much more affected by the environment than by fishing and that predators target small forage fish that are generally unaffected by fishing.
The waters of the Gulf belong to everyone…recreational fishermen, boaters, commercial fishermen, and those involved in oil and gas production. These waters are not the proprietary asset of any one group or special interest no matter how politically active, influential and well funded they are.
Louisiana’s menhaden fishery companies and processors are committed to sharing the Gulf side by side with others who have an equal right — but no more — to access the Gulf for their own personal or commercial interests.
Endorsements
"Louisiana's recreational and for-hire charter fishermen have suggested there need to be arbitrary and scientifically unsubstantiated limits on commercial fishing, including shrimping and Gulf menhaden fishing, to reduce incidental bycatch of speckled trout and redfish. While conservation efforts of these stressed species are important, singling out the commercial fishing sector without addressing the root causes of reckless overfishing by the tens of thousands of unmonitored anglers off Louisiana’s coast is misguided. Louisiana’s commercial fisheries follow sound fisheries management practices. We are heavily regulated, guided by science and sustainability. We will not allow others to selectively shift blame to us when they need to do more to preserve and protect their catch."
"Louisiana’s oyster industry stands with our colleagues on menhaden fishing boats and in the last two remaining pogie plants. This industry deserves to be protected and not regulated out of existence."
“We rely heavily on our industry throughout Plaquemines Parish to utilize and support our facility and services. We recognize Westbank Fisheries as a major employer for Plaquemines Parish. We work very closely daily with our community's entire menhaden industry population. Whether it be the employees or family members, Westbank Fisheries is a significant resource for Plaquemines Parish. We appreciate their presence and look forward to working with them for many years.”
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The Gulf menhaden (Brevoortia patronus) is a small marine filter-feeding fish. Common names include pogie and shad. It is small oily-fleshed fish, bright silver in color and characterized by a large prominent black spot followed by a series of smaller spots. Menhaden are flat, have soft flesh, and a deeply forked tail. Gulf menhaden are commonly 8 to 12 inches long and vary in weight. Gulf menhaden have a 3 to 5 year lifespan.
Gulf menhaden are found from Florida to Texas but predominately centered around the Louisiana coast and Mississippi River and Atchafalaya River estuaries where nutrients and plankton are high. As a result of coastal land loss, inland waterways are much larger now resulting in more area for Gulf menhaden to reproduce and thrive along the Louisiana coast. Adult and juvenile Gulf menhaden form large, dense, near-surface schools primarily in estuaries and near shore water from early spring through fall.
Gulf menhaden is considered an important species of the marine ecosystem due to its productivity. An adult Gulf menhaden can release more than 350,000 eggs in a single year. Gulf menhaden play a central role in the coastal ecosystem of the Northern Gulf of Mexico. Gulf menhaden are high-quality forage fish, meaning they transfer energy from primary producers (such as algae and phytoplankton) to upper trophic levels, providing predators with nutrients, vitamins and oil.
NO. Gulf menhaden are not considered suitable for human consumption. Gulf menhaden are too oily and bony.
The commercial Gulf menhaden industry uses the purse seine fishing system to harvest the resource. This method is less likely to result in large amounts of incidental bycatch or cause damage to the ocean floor. Here is the process:
A March 2022, economic study funded by the Science Center for Marine Fisheries, National Science Foundation, shows that the menhaden fishery in Louisiana and Mississippi generates $419 million in yearly economic output while supporting 2,059 direct and indirect jobs. It also found that the industry generates around $25 million in state and local tax revenues. Wages surpassing $50,000 per year, alongside benefits. As essential sources of stable income, the two Louisiana menhaden processing plants play a vital role in supporting families within these rural communities.
YES. Louisiana’s menhaden industry is rigidly monitored and regulated by numerous federal and state bodies including: National Marine Fisheries Service (NMFS),Gulf States Marine Fisheries Commission (GSMFC), Louisiana State Legislature, and the State of Louisiana Department of Wildlife and Fisheries (LDWF). The industry is certified by the Marine Stewardship Council (MSC), a credible third-party non-profit organization that sets standards for sustainable fishing which must demonstrate they are well-managed and sustainable compared to the MSC’s rigorous standards. Together, these agencies ensure the highest standards of environmental excellence and the protection of the menhaden resource.
Since 1964, NMFS has had access to the catch at each of the processing plants for biostatistical and stock assessment purposes. menhaden companies report daily vessel unloads to the NMFS on a daily or weekly basis throughout the seven-month fishing season. Vessel captains complete Captain’s Daily Fishing Reports, the daily logs of each vessel’s activities which include an at-sea catch estimate, fishing location, set duration and weather conditions for each and every set. Compliance is 100% and they are provided to NMFS on a weekly or bi-weekly basis throughout the fishing season. Beginning in May 2023, the menhaden industry began reporting monthly to LDWF on location, estimated volume of harvest and length measurements specified by the department. In 2024, LDWF will begin annual reporting to the Louisiana State Legislature on the commercial menhaden harvests.
Regulated State Lines Separating Louisiana's Inside/Outside Waters: Louisiana’s state waters are divided into inside and outside waters for management purposes using two lines, the “Inside/Outside Shrimp Line” and “Double Rig Line”. The state uses this line to regulate several fishing sectors including the Menhaden Industry. These lines follow the coastline from Texas to Mississippi. Waters landward of these two lines are inside waters; waters seaward out are outside waters. The Menhaden Industry has for decades being limited to fish only in the outside waters. Because of Louisiana’s dynamic coastline of ever-changing marshes, barrier islands, deltas and bays, there are significant areas of water restricted from being fished. Our neighboring coastal states do not have similarly restricted inland waters.
3-Mile Buffer Zone Around Grand Isle: For over a decade, the Menhaden Industry took proactive steps to protect Grand Isle by maintaining a voluntary 3-mile buffer zone to minimize its impact on this inhabited barrier island’s coastal community. This buffer zone begins at the eastern shore of Belle Pass to the eastern shore of Caminada Pass requiring a 1-mile buffer, the area from the eastern shore of Caminada Pass to the eastern shore of Barataria Pass requiring a 3-mile buffer along Grand Isle, and the area from the eastern shore of Barataria Pass to the eastern end of Grand Terre Island requiring a 1-mile buffer. This 3-mile buffer zone around Grand Isle exceeds other neighboring states. Westbank Fishing fully supported this buffer zone being codified into state law last year.
1/4-Mile Buffer Zone Coastwide: In 2022, the LWFC enacted an additional ¼-mile buffer zone from the “Inside/Outside Shrimp Line” and “Double Rig Line”. There was no environmental or scientific reason to justify this decision. It was done to address the user conflict issue that the recreational and for-charter fishing community has unjustifiably created to blame our industry for their overfishing. It is a higher and more restrictive standard than any other Louisiana commercial fishery.
Abandonment of Purse Seine Gear: In 2022, the State of Louisiana established rules to prohibit the waste of fishery resources and abandonment of menhaden purse seine gear during fishing operations, including: a 48-hour window to remove all gear before it is considered abandoned, gear marking requirements to facilitate retrieval and warn of navigational hazards, require notification to LDWF within 2 hours of any release of menhaden, require reasonable attempts to retrieve menhaden and bycatch from the environment in the event of a release, and define civil fines for commercial littering violation.
Bycatch Restriction: The State of Louisiana restricts bycatch to no more than 5% by weight, of any species other than menhaden and herring-like species.
Close the Season: If it was determined that the menhaden was being overfished, LDWF has powers under Louisiana Revised Statues Title 56 through its commission to close finfish seasons.
The estimated menhaden population is over 124 billion fish. The menhaden reduction fishing industry’s landings account for only about 1 to 2% of the total estimated menhaden population.
Louisiana’s regulated menhaden fishing season is only 7 months (April – October) allowing the stock to reproduce and replenish itself. Westbank Fishing voluntarily shares Louisiana coastal waters with recreational boaters and fisherman by limiting fishing to weekdays and doesn’t fish on major holidays.
NO. According to GSMFC’s most recent 2021 Stock Assessment Report, menhaden is “neither overfished nor experiencing overfishing” and there is “little risk” of it occurring. According to the GSMFC, population growth of the menhaden stock is believed to be reliant more on prevailing environmental and oceanographic factors during crucial development periods, such as the egg and larval stage, rather than biomass of mature females in the stock. The stock assessment is conducted every three years. The next stock assessment will be in 2024. In the event a single season results in menhaden landings of more than 750,000 tons, an automatic stock assessment will be triggered for the following year.
According to NMFS, in a June 7, 2023, letter to Louisiana Senate Natural Resources Committee Chairman State Senator Bob Hensgens, the menhaden stock is healthy, and it is unlikely that overfishing is occurring. According to LDWF, Menhaden are not overfished.
Studies dating back to 1977 when there were many more vessels involved in harvesting menhaden also prove that fact. Moreover, in 2019 the menhaden fishery was certified “sustainable” by the MSC. This certification came after more than two years of detailed review by an independent assessment body, extensive peer and stakeholder input and the final approval of an independent analyst.
The federal government enacted the Magnuson-Stevens Act to promote the U.S. fishing industry’s optimal exploitation of coastal fisheries to achieve maximum sustainable yields under existing environmental conditions.
NO. Demands for even more regulation have no merit. A May 2021 study published in Conservation Biology concluded that adopting extra-precautionary catch limits on forage species like menhaden is unlikely to result in higher predator populations. A similar 2017 study published in Fisheries Research, found that increases in predator populations were not correlated with increases in forage abundance, that forage species are much more affected by the environment than by fishing and that predators target small forage fish that are generally unaffected by fishing.
Today, only two menhaden fishing fleets and processing plants operate in Louisiana (Westbank Fishing/ Daybrook Fisheries and Omega Protein). Over the last 70 years, the industry has shrunk considerably. During the menhaden industry’s peak in 1984, there were more than 80 boats fishing in Louisiana coastal waters. Today there are approximately 30 boats operating.
According to analysis conducted by the Science Center for Marine Fisheries in March 2022, using raw catch data based upon Captain’s Daily Fishing Reports (CDFR) submitted to NMFS for years 2015 to 2019, 19.1% of the total menhaden catch is caught within 0.5 miles of Louisiana/ Mississippi coasts.
Miles from Shore | Observations (Number of Sets) | Total catch (000s Fish) | Average Catch Per Set | Percent of Total Catch |
---|---|---|---|---|
0-0.5 | 14,208 | 1,526,647 | 107.45 | 19.1% |
0.5-1.0 | 11,331 | 1,058,119 | 93.38 | 13.3% |
1.0-3.0 | 29,005 | 2,813,229 | 96.99 | 35.3% |
>3.0 | 25,546 | 2,577,916 | 100.91 | 32.3% |
Total | 80,091 | 7,975,911 | 99.58 | 100% |
Creating an exclusion zone within 0.5 miles from shore would have dire economic impacts, impacting 410 jobs that total $36.8 million in annual income. The menhaden industry is a marginal business with operational fixed costs including fuel, maintenance and crew. Few businesses could survive a nearly 20% cut in revenue. Pushing the industry further offshore will drive up costs, putting good paying jobs and Louisiana coastal communities at risk, including a loss of $5 million in annual business generated taxes.
Miles from Shore | Employment (Jobs) | Labor Income (million$) | Value Added (million$) | Output (million$) | Business Tax (million$) |
---|---|---|---|---|---|
0-0.5 | 410 | $36.8 | $61.6 | $83.5 | $5.0 |
0.5-1.0 | 271 | $24.3 | $40.7 | $55.1 | $3.3 |
1.0-3.0 | 719 | $64.6 | $108.2 | $146.5 | $8.8 |
>3.0 | 659 | $59.2 | $99.1 | $134.3 | $8.1 |
Total | 2,059 | $184.8 | $309.6 | $419.3 | $25.3 |
The commercial menhaden industry is a low margin business and subject to market fluctuation. While sunk operating costs can be amortized, profitability is not guaranteed as no fishing season is the same. Fishing further offshore will lead to higher operating costs including increased fuel and equipment costs and increased risks for fishermen including longer working hours and safety concerns in deeper water. These factors will affect profitability and long-term sustainability for the industry. The menhaden industry supports over 2,000 good paying jobs in communities where it is getting harder and harder to make a living. Why put these jobs at risk when all available science shows that the menhaden industry is not to blame when it is recreational fishermen who are overfishing finfish.
Louisiana’s menhaden reduction fishery provides upwards of 40% of the nation’s menhaden. But menhaden is a global commodity, making passing costs on to consumers nearly impossible. We are a price taker, not a price setter. If we raised prices, we would not influence the cost of the market.
NO. According to the Gulf States Marine Fisheries Commission, harmful algal blooms like red tide are mostly the result of increased nutrients flowing down rivers into the Gulf, not a lack of planktivorous fish. Many bays and estuaries in the U.S. are polluted with an overabundance of nitrogen and phosphorus that comes from runoff from land. These substances come from fertilizers, detergents, and other chemicals that find their way into coastal waters and, along with sunlight, feed the phytoplankton populations until they expand to huge numbers. As these dense blooms die, they sink and begin to decompose, stripping the oxygen from the water. The result of this decomposition is hypoxic water conditions or dead zones, the largest being in the northern Gulf every summer. Menhaden do not have the capacity to reduce unwanted phytoplankton blooms that arise from manmade sources, primarily because they eat mostly zooplankton. Menhaden are sensitive to environmental stressors and will avoid hypoxic areas like the Gulf dead zone. Studies have shown that they have little impact on water quality - and may even add more nutrients to the water than they remove.
Commercial menhaden reduction fishing is known to result in some incidental bycatch of finfish, although the amount can vary depending on the fishing method used, the location, and other factors. According to a 2020 LDWF analysis, estimated incidental bycatch rates of speckled trout are less than one tenth of one percent. For red drum, the estimate is 2.1%. The State of Louisiana restricts bycatch to no more than 5% by weight, of any species other than menhaden and herring-like species. To further analyze the issue, the Gulf States Marine Fisheries Commission is conducting a $1 million study to sample and describe both released and retained, non-target species from purse seines during the regular 28-week fishing season (April - November). As the commercial menhaden industry’s regulatory body, it is imperative that this study be conducted before any arbitrary restrictions are instituted. Science should guide this process, not politics.
The menhaden industry peaked in 1984, with more than 80 boats operating, catching over 980,000 metric tons. When compared to NOAA’s last data for recreational fishing in 2013, only 497,500 metric tons of menhaden were caught. Meanwhile, the recreational fishing sector’s angler trips and landings of red drum and speckled trout has skyrocketed between 1984 and 2013. Extrapolating this exponential growth over the last ten years would indicate that the rapid proliferation in the recreational fishery would indicate it may be the cause of pressure on the speckled trout and red drum species.
Louisiana Data | 1984 (Peak of Menhaden Fishery) | 2013 (Last NOAA Data for Recreational Fishery) | Percentage Change |
---|---|---|---|
Menhaden Effort Vessel Ton Weeks | 645.9 | 332.5 | 49.4% ↓ |
Menhaden Landings Metric Tons | 982,800 | 497,500 | 51% ↓ |
Recreational Effort Angler Trips | 6,511,012 | 10,770,452 | 65.4% ↑ |
Recreational Landings Red Drum | 4,112,291 | 15,724,555 | 282.4% ↑ |
Recreational Landings Speckled Trout | 3,186,320 | 35,420,652 | 1,011.6% ↑ |
NO. According to a 2021 study by the Science Center for Marine Fisheries, for many menhaden predator species, like speckled trout and red drum, extra-precautionary management of forage fish is unlikely to bring additional benefits. The study found that sustainable limits already employed are sufficient for maintaining forage fish abundance above thresholds that are necessary for their predators. That is because predators like speckled trout and red drum are highly mobile, have high diet flexibility and can go and look for forage fish in places where they are abundant or eat another species. Predator fish breed in places where there is high and stable forage fish abundance. The menhaden resource is well managed and closely monitored. Pressure on speckled trout and red drum species populations is not because of menhaden reduction fishing. No science says menhaden reduction fishing bycatch is causative of predator issues or impacting the ecosystem.
NO. This number is more than misleading. Experienced fishery managers have never estimated bycatch for the purse seine fishery anywhere near 3 percent by volume. Most experts agree that the figure is near or less than 1 percent. The CCA Louisiana have extrapolated their false percentages to tens of millions of pounds of "trout, redfish, drum, shrimp, mullet, croaker, catfish, and more" - an example of irresponsible advocacy that would not be accepted by any respectable fisheries scientist. Bycatch of spotted sea trout and red drum from the menhaden fishery average 0.07 percent and 2.1 percent, respectively, when compared to total Louisiana recreational fishing landings of those species, according to a 2020 analysis by the state- hardly enough to have a major impact on those fisheries.
It is inaccurate and misleading that CCA Louisiana claims this is a “NOAA study.” Only one author is an employee of NOAA. The authors specifically state that this work should NOT be considered the views of any governmental entity. According to LDWF staff, this paper describes a modeling approach to ecosystem-based fisheries management for menhaden but should only be one consideration when developing fisheries management recommendations/decisions. This paper should not be used alone to base management decisions, especially those decisions involving catch advice (e.g., setting an annual harvest limit for menhaden). The authors recommend a multi-model approach, like that utilized for Atlantic menhaden, should be used to inform catch advice in the Gulf fishery.
LDWF staff reviewed this study and interviewed its authors. They made the following conclusions:
In the study’s own next steps for management considerations, it states that additional data must be obtained to reduce uncertainties in the model, specifically trophic interactions data. Any model must undergo a technical peer review process to help build trust in the process and fine-tune data inputs via a collaborative process including other stakeholders and scientists.
To lay the groundwork for the Atlantic States Marine Fisheries Commission’s recently implemented ecosystem model, biologists work began twenty years ago. But Its ecosystem reference points for Atlantic menhaden focused on the needs of striped bass, which is both a major predator and the focus of the coast’s primary recreational fishery. The Gulf has no single species with similar status, meaning multiple fish will need to be thoroughly studied to establish the necessary ecosystem reference points.
The menhaden fishing industry supports the development and implementation of Ecosystem Based Management. It recognizes the importance of managing marine resources on an ecosystem basis, as all species within the Gulf interact with one another to a varying extent. While there is broad support for, one of the current challenges in adopting this new system is accurately accounting for the complex interactions between predator and prey species. This includes everything from phytoplankton at the base of the food chain, to apex predators like sharks at the top of the pyramid of trophic relationships.
Establishing an ecosystem model of the Gulf is incredibly complex. This is just one study and should not be the basis for making any final determinations or influence any political considerations to arbitrarily regulate the menhaden industry.