NATIONAL COALITION FOR MARINE CONSERVATION

4 Royal Street, S.E., Leesburg, VA 20175

March 8, 2012

Margo Schulze-Haugen

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)

Dear Margo,

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.

Sincerely,

Ken Hinman

President