Highly Migratory Species Report
by John T. Koegler
(from Jersey Coast Anglers Association January 2003 Newsletter)
Angler Bluefin Tuna transferred to General Category
Never in the history of NMFS regulations of recreational fisheries has it been more important that you take a minute and write a short note to save these HMS fisheries.
There are two major topics that need responses immediately. Foremost is the major reallocation of Angler bluefin tuna quota to the General Category for the second year in a row. Also part of the transfer issue is the petition to open a NEW WINTER General Category (GC) Giant Bluefin Tuna fishery for North Carolina.
The North Carolina fishery issue is key because the North Carolina Division of Marine Fisheries has sent a petition to NMFS that requests the creation of a NEW General Category Winter sub quota in the Giant fishery. They asked for 23% of the US GC quota
The main problem with the entire issue is that the quota that made this fishery possible came form the Angler quota reallocation, not General Category quotas. Uncaught Angler quota rolls over from year to year if not landed. By eliminating this quota rollover reserve next year’s Angler rules cannot be liberalized. As a direct result of these transfers Anglers will NOT have a better opportunity to land their assigned quota. This is the second year in a row that 60 MT of Angler fish have been given to the General Category. There would have not been enough quotas remaining for any North Carolina fishery if NMFS had not robbed Angler quota and given it to General Category.
The Ugly Facts.
At the end of the 2001 season NMFS transferred 60 MT of Angler quota to General Category. This was not used and General Category had 107 MT left for 2002.
BUT 60 MT of that was Angler bluefin quota.
At the end of the current 2002 year NMFS transferred an additional 60 MT to General Category. Later in November, NMFS took an additional 15 MT and transferred that also to General Category. These transfers provided the quota for a NEW wintertime Giant GC fishery in North Carolina which was allocated 60 MT.
The late October Giant fishing from Mass. Ports was hot. The GC went way over their quota, even though 60 MT had previously been transferred from Anglers. To keep within quota and not reduce GC quota next year, NMFS transferred all remaining quotas to General Category. They did this by a second transfer on November 25, 2002 transferring:
10 MT from Longline North
15 MT from Anglers,
15 MT from Harpoon
65 MT from reserve
10 MT from the NY Bight fall fishery.
This was in addition to the previous transfers of 130 MT made on October 16, 2002
60 MT came from Anglers
70 MT came from Longline
130 MT. was the amount of the October 2002 transfer
115 MT was the amount of theNovember 2002 transfer
245 MT of other gears bluefin was transferred in 2002 to General Category.
Take away the 60 MT. just assigned to North Carolina and the remaining 185 MT is the amount General Category went over their 2002 quota.
The issue is that NMFS took Angler quota in 2001. When it was not landed in 2001 it was not returned. As a result the rules for Anglers were not loosened in 2002 and Anglers could NOT catch their assigned quotas under NMFS strict recreational rules. Now, the Angler quota reserve has been totally eliminated by assigning it to General Category. It is this reallocation of other people’s assigned quotas which has permitted a North Carolina winter GC fishery to open. Talk about the Grinch stealing Christmas! The Grinch was a piker compared to NMFS.
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TAKE A KID FISHING
Most of the Bluefin caught in December in recent years by North Carolina fishermen has been Angler allocated small medium bluefin tuna that were less than 73 inches long. So not only do Anglers lose quota but the fish needed for Angler fishing in following years is being destroyed to catch a Giant, which may not have even been there!
Please, please write a letter on No Winter GC sub quota as soon as possible. December 18th was the date suggested.
HMS Management Division
One Blackburn Drive
Gloucester, MA 01930-2298
Additionally, label the letter “Comments on Petition for Rulemaking.”Fax number is 1-978-281-9340
NMFS usually takes 90 days or longer to answer any rulemaking petition. Note the time allocated to answer this petition is only 30 days.
A copy of your original note should be sent to:
HMS division F/SF1
1315 East-West Highway
Silver Spring, MD, 20910
NMFS requests comments on options to Manage Atlantic Shark Fisheries
NMFS is seeking comments on recreational management options including retention limits, minimum sizes, authorized gear and landing requirements.
You need to send a letter supporting two sharks as limits in place of one. I am not sure what authorized gear refers to but you can bet your long johns that the authorized gear issue means new limits on your future shark fishing unless you respond.
It is strange that NMFS would advocate and support the existence of any directed commercial shark fishery. Shark populations have never been able to sustain their numbers when a directed commercial fishing targets them.
In NMFS’s 1993 report on sharks it is clearly stated that no commercial shark fishery has ever been sustainable. The Magnuson Act requires that a fishery be sustainable. In fact, the Magnuson Act is also known as the Sustainable Fishery and Management Act.
However, NMFS has continued to ignore this issue in their shark management choices. Have they not failed in their management by allowing any directed commercial fishery to Exist? NMFS has greatly compounded their awful error by supporting the massive export of shark fins to the Orient where shark fins are cooked into a premium soup.
Ending the directed commercial shark fishery and especially the shark fin fishery is NMFS responsibility. NMFS response has been typical of their entire management history. They have fully supported many new commercial fisheries knowing full well that these new fisheries would never be sustainable. Currently NMFS is allowing shark fins to be sold in far higher numbers and pounds than their current regulations legally allow.
Their management rules clearly state that fins cannot be over 5% of the weight of a shark landed. This was supposed to be THE big advance in management needed to control live shark fining. Lots more shark fins are being reported sold than NMFS 5% rule allows. Why? IS NMFS using selective enforcement or no enforcement at all on this issue?
It took until the year 2000 for NMFS to require the commercial reporting of shark fins sold. NMFS latest shark fin sale numbers are shocking. Shocking in that numbers of pounds of fins being reported clearly documents that the shark fishery is not properly managed.
It is possible that the shark meat is landed as required and then discarded? However, this action would be a terrible waste of a valuable ecosystem control system. This will allow the entire ecosystem control by sharks to be ended. The final result will be the planned recovery of desired and valuable finfish stocks and other seafood products such as scallops, clams and crabs will never reach their planned sustainable levels. This is because a dangerous predator’s population previously controlled by sharks has exploded and their numbers are totally out of balance.
The direct effect of shark overfishing on a properly functioning ecosystem is devastating. All direct commercial shark fisheries must be immediately stopped.
The affect of this loss of predator controls was clearly documented this past summer. New Jersey surf fishermen were overwhelmed by huge schools of cow-nosed rays cruising the beaches. They were eating every offering for over two weeks, a clear indication that a species when there is no directed commercial fishery explodes in numbers when their chief enemy, the Large Coastal Shark , is commercially overfished.
This overfishing has already occurred in the spiny dogfish fishery. Regulations now limit this directed fishery to such a low trip limit and quota that it is only a bycatch fishery. The problem is the base population of the spiny dogfish is still two to three times higher than any of their historic population numbers. They have got to eat something and these dogfish are not docile quiet sharks but very effective predators. Are they directly responsible for the failure of many other cold water finfish species' failure to recover?
Send your comments to:
HMS division F/SF1
1315 East-West Highway
Silver Spring, MD, 20910
Labeled “Shark comments”