What NMFS Needs to do for Bluefins
NATIONAL COALITION FOR MARINE CONSERVATION
4 Royal Street, S.E., Leesburg, VA 20175
March 8, 2012
Chief, Highly Migratory Species Division
National Marine Fisheries Service
1335 East-West Highway
Silver Spring, MD 20910
RE: Pre-Scoping on Amendment 7 (Bluefin Tuna Management)
I am unable to attend Tuesday’s meeting of the HMS Advisory Panel, so I am submitting the following written comments on behalf of the National
Coalition for Marine Conservation (NCMC) for inclusion in the meeting’s record
of discussion of Bluefin Tuna Issues and Options.
The NCMC urges the National Marine Fisheries Service to use
Amendment 7 to the Atlantic HMS Fishery Management Plan to strengthen
protections for severely overfished bluefin tuna, with emphasis on the western
bluefin’s breeding ground in the Gulf of Mexico. As stated in our previous
comments on last year’s “weak hook” final rule, we believe this measure is
commendable but ultimately an inadequate response to the serious problem of
longline bycatch of spawning bluefin.
We propose that Amendment 7 explore options for minimizing longline
bycatch of bluefin in the Gulf, notably the use of a time-area closure (1) and a
bycatch cap (2), either separately or in tandem. Both measures would in turn
provide a strong incentive for the use of alternative gears or fishing strategies (3).
1) Longline Time-Area Closure in the Gulf of Mexico
Option: Close an area of the north central Gulf of Mexico to all pelagic
longlining, corresponding to the area designated a bluefin Habitat Area
of Particular Concern, during the months of April, May and June to
minimize the incidental capture of breeding bluefin tuna. This closure
would be enforceable because all longline vessels carry vessel monitoring
systems (VMS) and would not require observers.
A time-area closure in the Gulf, which would significantly reduce bluefin
bycatch while allowing for fishing in other months, has been proposed and
considered in previous rules pertaining to Atlantic bluefin tuna
conservation. The closure option has received, and continues to receive,
considerable support from stakeholders, including NCMC. The area to be
closed has been identified through designation of the Bluefin HAPC
because of its critical importance to spawning, and the time defined as the
peak spawning months of April through June.
2) Longline Bycatch Cap in the Gulf
Option: Establish a Gulf of Mexico fleet-wide cap on longline bycatch of
bluefin tuna to create a disincentive to interact with bluefin in the Gulf
during spawning season. The cap would be a hard cap, landings plus
discards, and when reached, the Gulf would close to longlining for the
remainder of the year.
An annual cap on incidental catch of bluefin tuna (landed and discarded)
has been proposed as an alternative within the HMS Advisory Panel (see
Summary of the September 2010 meeting – “Priorities: Bluefin Tuna –
Reduction of PLL and Bluefin Tuna Interactions – explore weak hook
implementation and bycatch caps”). NCMC proposed this alternative in
our comments on the bluefin ANPR in August 2009. A regional cap could
be set, for example, to achieve a 75% reduction from recent levels. When
the cap is reached, the Gulf would close to longlining for the rest of the
year. A bycatch cap would create an incentive for tuna and swordfish
longliners to alter their fishing strategies or switch to more selective
alternative gears. (see #3 below, Alternative Gears)
3) Transition from Longlines to More Selective, Sustainable Alternative
Gears or Fishing Strategies
Option: Phase-out the use of pelagic longlines in the Gulf of Mexico and
transition the fleet to more selective, sustainable fishing gears such as
greensticks for yellowfin tuna and buoy gear for swordfish.
Either a 3-month closure during the height of bluefin spawning activity in
the gulf (1) or a hard cap on longline bycatch of bluefin (2), or the two in
combination, would maximize protection for breeding bluefin, while
providing an incentive for longliners to switch to more selective
alternatives or modify their fishing strategies to minimize bluefin
mortality. Greenstick gear for tuna and buoy gear for swordfish have both
been shown to have high catch rates of target species with insignificant
1 This option would require enhanced observer coverage. However, we note that observers will
be needed to continue monitoring the results of what NMFS clearly describes as an ongoing weak
hook experiment with many questions yet to be answered about its effectiveness.
amounts of bycatch of any species. NMFS should consider a
complementary action through Amendment 8 to expand non-longline
permits for swordfish.
Thank you for considering these options as you prepare a public scoping
document for Amendment 7.