To all US Recreational and Commercial hand gear fishermen:
RECREATIONAL FISHING ALLIANCE and the AMERICAN BLUEFIN TUNA ASSOCIATION urge you to send your public comment to NMFS on Amendment 7.
For decades, US Gulf and Atlantic longliners targeting swordfish and yellowfin have incurred substantial annual incidental bycatch of over 80 different species, including bluefin tuna ranging from young juveniles to giant bluefin. This problem has resulted in hundreds of tons of bluefin bycatch each year for at least three decades.
Several years ago, as an accommodation to the longliners, the National Marine Fisheries Service granted them an allocation of 8.1% of the US bluefin quota, enabling them to retain and sell bluefin bycatch. However, in the year in which it was implemented and for every year since, this 8.1% allocation has proven to be woefully inadequate. Bluefin bycatch in the longline fishery has been uncontrollable and NMFS has taken very few steps to reduce bycatch.
Longstanding regulations require that bluefin caught by longline in excess of the 8.1% allocation must be discarded, most often dead, and allowed to sink to the bottom of the ocean. As a typical example, last year longliners were allowed to keep and sell a maximum of 89 mt of bluefin, but they exceeded the adjusted quota by 218%, requiring them to discard an estimated 239 mt of bluefin, the equivalent of approximately 25% of the total US quota.
This wasteful practice should be addressed, first and foremost, by putting regulations in place intended to rigorously restrict this excessive and uncontrolled incidental bycatch.
A recent ICCAT Recommendation requires the US and all other Atlantic bluefin fishing countries to account for all forms of bluefin mortality, including bycatch and discards, within each country’s quota allocation.
In order to comply with this requirement, NMFS has drafted a proposal called, Amendment 7. The centerpiece of this complex proposal is the concept of converting all longline bluefin discards to legal landings by making it illegal for longliners to discard bluefin over 73 inches in length.
NMFS’ preferred alternative for achieving this in Amendment 7 would strip quota from all other user categories such as the Harpoon, General and Angling Categories – categories that fish sustainably – and apply it to the longline category, resulting in a massive reallocation of bluefin tuna to the longliners. This presents a clear and unambiguous threat to all the traditional US handgear bluefin fisheries.
NMFS has asked for public comment on Amendment 7. RFA and ABTA urge you to send the below letter to NMFS now, letting NMFS know how you feel about Amendment 7. The deadline for public comment is January 10, 2014.
Here’s how to send the below letter:
- Copy the entire letter below.
- Click on this link. It will take you directly to regulation.gov, to a page that contains a window for comments. Paste this letter into the comment field. Then, fill in your name and click on “Continue”.
- At the bottom of the next page, click in the box that says, “I read and understand the statement above”.
- Click on, “Submit Comment”. You are done!
Mr. Tom Warren
National Marine Fisheries Service
55 Great Republic Drive, F/SF1, Suite 02-200
Gloucester MA 01930
Re: Amendment 7 – Public Comment – NOAA-NMFS-2013-0101
Dear Mr. Warren,
Regarding Amendment 7, I am in favor of:
- Strictly maintaining the longline allocation for bluefin at 8.1% of the total US quota.
- Establishing a time-area closure in the Gulf of Mexico that closes this important area to longline fishing when bluefin tuna are present.
- Increasing the size and number of time-area closures in the Atlantic, preventing longliners from fishing in areas where they incur bycatch of bluefin.
- Establishing an annual bluefin bycatch “cap” for every single longliner in the US Gulf and Atlantic, the total of which not to exceed their 8.1% allocation.
- Maintaining the existing spatial and temporal framework of bluefin quota allocation for the recreational and commercial handgear categories.
- Establishing 100%, industry-funded observer or electronic coverage of every longline vessel in the US Gulf and Atlantic to ensure compliance.
- Effectively address the issue of “latent permits” in the longline fishery by eliminating the ability to re-activate these permits.
- Effectively addressing the ongoing requirement of discarding all juvenile bluefin caught in the longline fishery, a problem that would continue under proposed Amendment 7.
I oppose any attempt to give any of the Recreational and Commercial handgear quota to the longliners.
Thank you for the opportunity to comment on Amendment 7.