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Current ICCAT/NMFS Bluefin Tuna Dilemma
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02/28/09 |
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February 26, 2009
Dear Recreational Bluefin Tuna Angler:
In consideration of our request to have you attend the
National Marine Fisheries Service (NMFS) Hearing on March
4th (3:00 to 5:00 PM, Great Republic Drive, Gloucester, MA),
We have written this note which should provide a basic
understanding of the current situation, what is at stake,
and a possible short term strategy to protect US interests.
- NMFS HMS Advisory Panel Members, Steven James and Tom
Depersia
The problem –
The United States is signatory to ICCAT (International
Commission for the Conservation of Atlantic Tuna—a group of
20 nations plus the nations of the European Union (approx.
20 additional nations) and is bound by ICCAT mandates.
If US total BFT catch continues its current catch trend
(below ICCAT allocated quota), the US stands to lose
approximately 50% of its quota in 2011. This loss will be
felt across the spectrum of US tuna fisherman including both
commercial and recreational through our established
percentage quota shares of the total US quota ICCAT will
reassign the unused portion of the US quota to another
nation such as Mexico, Japan or Canada (it could even go to
Belize) in 2011. In a nutshell, 50% of a natural resource
that has traditionally been the livelihood of US Commercial
Fishermen and one that is highly regarded by recreational
anglers is in serious jeopardy of being permanently lost to
another country or countries.
While US commercial and recreational fishermen fish under
the most stringent and conservative self imposed regulations
of any country in the world, ICCAT’s longstanding “use it or
lose it” quota policy will serve to punish US fishermen for
being conservative and going above and beyond the call of
duty to rebuild Western Atlantic BFT stocks.
The US Commercial BFT retention limit is determined by NMFS
and it is currently set at 73”. While the US uses 73” as its
minimum commercial size, Canada, Japan and Mexico use the
ICCAT minimum length of just 45”. Thus, US fishermen are
required (by US/NMFS regulations) to release BFT that are
perfectly legal to sell in other countries that fish the
Western Atlantic. In essence, the United States’ unilateral
higher level of standards and efforts (73” minimum for
commercial fish) to preserve this magnificent fishery will
result in not only United States loss of quota, but also
will have a direct and immediate negative impact on the
restoration of the bluefin population (decimation of
juvenile fish).
If the US BFT quota is reassigned because we can’t fill the
2009 and 2010 quota, it will most surely be assigned to a
country that uses 45” as its minimum commercial length.
Further, any country that receives the US unfilled quota
will be able to fish the 45” limit until the end of the
stock rebuilding program which ends in 2018! This is likely
to result in our US giant BFT quota being filled by another
country with thousands of juvenile fish. If this whole thing
seems unfair, it is because it is terribly unfair and a very
inefficient if not impossible way to rebuild a fish
population!
Clearly the US needs to convince ICCAT that it should not
strip quota away from any country that chooses to fish under
more conservative guidelines than those established by ICCAT.
Unfortunately, this is a battle that will need to take place
at the next 2011 ICCAT meeting as the rules are already
established for 2009 and 2010. But a similar battle will be
waged over loss of US swordfish quota this November 2009
because the US has not caught its swordfish quota in many
years.
Because of ICCAT’s “use it or lose it” policy, the US long
term biological goals of BFT stock rebuilding need to take a
back seat to our short term political problems (quota usage)
or the fish stocks that we have fought to preserve and
rebuild are simply going to be reassigned to other nations.
In essence, our past fishery management effort s will have
been largely in vain unless we can land most of the US 2009
and 2010 quotas.
The United States’ ability to reach the 2009 quota is
absolutely critical as the 2010 fishing year will not have
concluded when the 2011 ICCAT meeting begins.
Unless something is done, transfer of US allocation to other
nations will result in two very bad things—the permanent
loss of United States allotted tuna catch (both commercial
and recreational), and a significant reduction in tuna
population via ICCAT approved commercial take of 45” by
nations to whom that transfer is made.
The proposals -
Proposal 1 - Augment existing commercial retention limits
with 65+ inch BFT as a temporary measure until either the
availability of giant BFT become more plentiful or ICCAT
recognizes the sacrifices of US fisherman (73” minimum) and
subsequently changes the threatening measures to countries
that fish with stricter standards than current ICCAT
requirements.
The specific allocation caps for each category will be
determined by the result of a mortality neutral formula. The
intent is to maintain the current level of mortality by
catching a predetermined amount of smaller fish at an
overall predetermined lower quota level. Simply put, to
catch more smaller fish to meet our quota we have to give up
giant quota to keep the rebuilding plan on track.
This will entail determining how much uncaught BFT is at
risk for transfer as a result of ICCAT policy, then complete
the calculations needed to evaluate the neutral mortality
option and then manage the specific allocation cap through a
working group supported by NMFS. These results would then go
to hearing for 2009 effort control.
Proposal 2 - Allow General Category BFT fisherman to
determine landings based upon the number of days of any
given trip. Currently there is a landing limit of three BFT
per vessel per day with no consideration given for long
range trips in the General Category. By allowing multi-day
trips to retain more than 3 BFT, areas of offshore fishing
that have been economically off limits due to operational
overhead may become obtainable.
Proposal 3 - Increase the number of BFT retained by
Recreational Anglers from one fish to two fish per day.
Specifically, one fish between 27” and <47” and one fish
between 47” and <73”.
Proposal 4 - Allow Charter/Headboat Category fishermen to
fish both recreationally and commercially in the same day
and on the same trip.
Recreational Implications –
The US Recreational BFT quota has historically been
determined by NMFS as a percentage of the overall US quota.
Currently, the 2009 BFT Recreational Category quota is 19.7%
of the US baseline quota. Because the Recreational quota is
based upon the overall US quota, any US BFT quota that is
re-assigned to another country by ICCAT will be felt in all
Categories including the Recreational Category. Current
Recreational size, quantity, and probable fishing season
will be dramatically altered. Therefore, it is essential
that General Category, Harpoon Category and the Recreational
Category BFT fishermen work closely together to try to
achieve the 2009 and 2010 US quotas.
Based upon historical landings data, the US has not reached
its’ yearly ICCAT BFT quota since 2003. Further, the US has
not been able to reach more than 50% of its’ ICCAT BFT quota
since 2005. If the recent BFT yearly landings are an
indicator of the 2009 landings, it would appear that we will
be off by more than 50% of the US BFT quota unless something
is done to remove or modify the overly strict effort
controls imposed by the National Marine Fisheries Services.
Because the 65” BFT retention proposal is a category
specific proposal (General Category and Harpoon Category),
the existing US Recreational quota and size limits will not
be affected by either proposal above. Therefore,
Recreational anglers will still be allowed one “Trophy” BFT
(73” or larger) per year if NMFS accepts the 65” proposal
above. Anglers will also be able to pursue their regular
full quotas of schoolies and small mediums.
Action Required –
It’s your fishery, be prepared to defend it. Attend the NMFS
Hearing on March 4th (3:00 to 5:00 PM, Great Republic Drive,
Gloucester, MA)
Send a copy of the sample attached letter to Sarah
McLaughlin at the NMFS Gloucester office.
You may submit letters and comments, identified by
"0648-AX12", by any one of the following methods: Electronic
Submissions: Submit all electronic public comments via the
Federal eRulemaking Portal http://www.regulations.gov Fax:
978-281-9340, Attn: Sarah McLaughlin Mail: Sarah McLaughlin,
Highly Migratory Species Management Division, Office of
Sustainable Fisheries (F/SF1), NMFS, 55 Great Republic Dr.,
Gloucester, MA 01930
Cut and paste, modify to suit, and
send by before March 4th the below open letter.
February 26, 2009
Sarah McLaughlin
HMS Management Division
Office of Sustainable Fisheries (F/SF1)
NMFS
55 Great Republic Drive
Gloucester, MA 01930
re: “0648-AX12”- 2009 Atlantic Bluefin Tuna Quota
Specifications and Effort Controls
Dear Ms. McLaughlin:
I am writing to you to express my concern regarding the NMFS
proposed rules pertaining to the 2009 bluefin tuna quotas.
In light of ICCAT’s “use it or lose it” BFT quota policy, I
ask that the NMFS assist US fishermen in every possibly way
to help ensure that this natural resource remains with US
fishermen.
I ask that NMFS ease effort control measures so that the US
fishermen, both recreational and commercial, have a better
chance of achieving the 2009 US BFT quota as specified by
ICCAT. Under the current NMFS BFT effort controls, the US
doesn’t harvest nearly enough bluefin tuna to fill the ICCAT
quota and unless something is done, transfer of US
allocation to other nations will result in two very bad
things—the permanent loss of United States allotted tuna
catch (both commercial and recreational), and a significant
reduction in tuna population via ICCAT approved commercial
take of 45” by nations to whom that transfer is made.
There are several measures that NMFS can take to help
increase in the harvest of US fishermen, these include:
1. Increase the number of BFT retained recreationally from
one fish to two fish per day. Specifically, one fish between
27” and <47” and one fish between 47” and <73”.
2. Allow the Charter/Headboat Category to fish both
recreationally and commercially in the same day and on the
same trip.
3. Allow the sale of BFT based on 65” CFL instead of 73”.
4. Allow General Category BFT fisherman to land up to three
fish per day for each day of the trip (i.e. 2 days = 6
fish).
I believe the implementation of these measures would help
enable US fishermen to reach their allotted quota and help
prevent ICCAT from transferring the quota to other
countries. The recreational sport fishing interests of
Americans are at stake along with thousands of US jobs.
Please ease the NMFS effort controls associated with BFT and
help the US retain this valuable natural resource.
Sincerely,
(your name &address)
Submissions: Submit all electronic public comments via the
Federal eRulemaking Portal http://www.regulations.gov
Fax: 978-281-9340, Attn: Sarah McLaughlin
Mail: Sarah McLaughlin, Highly Migratory Species Management
Division, Office of Sustainable Fisheries (F/SF1), NMFS, 55
Great Republic Dr., Gloucester, MA 01930
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© Offshore Pursuits LLC 2009 |
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