Highly Migratory Species Report

by John T. Koegler

(from Jersey Coast Anglers Association November 2005 Newsletter)

Highly Migratory Species Action Alert

There were two New Jersey HMS meetings held recently. One was in Cape May at Lower Township building on Sept 29, 2005 and the other at the Barnegat Light First Aid meeting room on Thursday, October 6, 2005. Both meetings had major turnouts of recreational people opposed to NMFS proposed new HMS regulations. There were 150 people at Lower Township and 202 at the Barnegat Light First Aid meeting. All but 8 at Barnegat Light were recreational. . This was a great attendance since in recent years less than 50 total interested parties attended these meetings.

At both meetings recreational interests made quality comments. Most recreationals covered the HMS White Marlin items. RFA spoke first and covered their position on White Marlin and Billfish Plan items. All attending supported their position.

Rick Weber gave an outstanding report at the Lower Township meeting. Dick Weber added additional items. Their main point was why destroy so many recreational businesses when recreational fishermen landed only 23 White Marlin in 2004. How could 23 Marlin make any difference in the conservation of White Marlin on an ocean-wide basis?  A very good question that NMFS has yet to answer?

Those who read NMFS 38 page Federal Register notice found no new specific commercial regulations were proposed. NMFS reported pelagic longline White Marlin dead discards were high. In 1998 longline boats reported 40 Metric ton of White Marlin discarded dead. Assuming each fish weighed 50 pounds that is 1,600 dead White Marlin. Later year’s had lower estimates but the lowest was 40 times anglers reported 23 landed white marlin.

JCAA’s speaker noted NMFS was proposing to approve two additional gear types that clearly affected White Marlin. The two new gears were Buoy gear, a longline substitute, and Green sticks. NMFS was proposing that Buoy gear could be fished legally in the areas currently closed to commercial pelagic longline gear. NMFS proposal to authorize new longline substitute gear in the HMS closed areas is an outrage beyond measure. How could NMFS approve new gear when NMFS reports all HMS fish are over fished?

JCAA at Barnegat Light commented on the proposed elimination of the recreational N/S dividing line. The N/S line has been part of bluefin tuna management for a long time and was written to achieve a fairer distribution of bluefin tuna landings. This rule was written so that one small area of the coast was not permitted to land the entire recreational quota, especially school bluefin tuna. This is an important issue not covered at the meetings by the other speakers and needs to be included in your comment letter.

Anglers must recognize that the proposed change in the bluefin tuna season start time from June 1 to January 1 will have a major impact on anglers’ quota allocations and the areas where they are landed. NMFS item # G2 proposes that “All HMS fisheries are managed on a calendar year (01 Jan- 31 Dec).”

NMFS stated reason is to make ICCAT reporting easier, in place of June 1 season opening. NMFS created this June season start rule about 15 years ago using similar reasoning. All Categories must recognize that a January 1 opening would permit North Carolina to catch a big part of the total US Bluefin quota before the recreational or commercial season begins. Is this not a dangerous proposal that affects recreational categories from Virginia to Maine?

Since 1994, North Carolina fishermen used the unlanded ICCAT quota from other areas when available. North Carolina was not part of the original US ICCAT quota allocations. Their winter bluefin tuna fishery did not exist until 1994. Do they deserve to be given a bluefin tuna quota stolen from long established fisheries?

JCAA will make written comment on mandating a winter General Category quota for the North Carolina. NMFS proposed a 3% increase for October/November quota and a 5.2% for December and 5.3% for January. It must be noted that when the original quotas were specified North Carolina was not part of the original quota allocation.

NMFS two new proposals will authorize a major quota transfer from other established area fisheries to North Carolina. In addition, there has been no reporting by NMFS of the winter recreational bluefin landings in North Carolina. Does a not NMFS proposal represent quota theft benefiting only North Carolina fishermen?

Finally, NMFS proposes to change all adjustments from Framework changes to FMP changes.  NMFS is proposing that all new changes in management quotas are FMP amendments, not plan changes. Does this not allow NMFS to make changes in the plans without requiring them to have a public comment period before applying them? Based on past experience this major revision must be rejected if there is any desire to maintain the way that ICCAT quotas were previously allocated.

There are a host of other issues covered by NMFS as housekeeping items. Several have major future impacts depending on how they are finally written. Anglers and their supporters better understand what these issues are.

Here are two proposals that anglers must question:

Table 1.5 Proposed Consolidated FMP

1- Objective #16 – NMFS is proposing in their FMP consolidation Plan to:

“Create a management system to make fleet capacity commensurate with resource status so as to achieve the dual goals of economic efficiency and biological conservation for both commercial and recreational fisheries, while reducing latent effort and over capitalization, as needed and providing access for traditional gears and fishermen to participate fully as the stock recovers.”  Should recreational interests support this item? Why? What do you think this proposal will do?

Item #14-Optimize the social and economic benefits to the nation by reserving the billfish resource for its traditional use, which in the continental United States is almost entirely a recreational fishery. Please explain what the word “almost” is doing in this paragraph.

HMS comments were to be sent by October 22, but the Gulf Storms have not permitted their HMS meetings to be held. NMFS has extended the comment period on HMS issues until March 1, 2006 at 5 PM.

JCAA will have a sample HMS comment letter on their web site (http://www.jcaa.org) by October 25. Copy it and send it into NMFS on these very important proposed regulations.

An overview

            Highly Migratory Species are by their very nature ocean crossing fish. Their crossing and recrossing of the Atlantic Ocean has been scientifically proven. The problem begins when NMFS tries to treat HMS fish management as local and then impose regulations as if these HMS fish are totally under their control. Even if NMFS decided to end all HMS landings by ALL US fishermen, such a closure will have no affect on the survival of any HMS.

 International cooperative management is key to saving all remaining HMS species. So fa, expecting the other ICCAT members will follow NMFS conservation lead is a waste of both time and effort. NMFS and US representatives have never been able to get the other fishing countries to observe their commitment to ICCAT rules and regulations. ICCAT’s member’s conservation commitment to sustainable fisheries does not exist.

            After 26 years of international failure to follow any of ICCAT’s rules, what happens next? The European and African countries have refused to observe their conservation commitment to ICCAT. After 26 years of refusal to observe their ICCAT commitments, how can the US delegates to ICCAT believe there will be a miracle that brings a major compliance change in the year 2006?

 Government people never want to admit their failures in public. But is it not absurd if not a total fantasy after 26 years of no compliance to expect ICCAT member countries to change?

US 2005 Bluefin tuna landings.

NMFS recently reported the US bluefin tuna landings from June 1 through August 31, 2005. It should be a surprise that US Commercial bluefin tuna landings are down sharply.  It is known that effort is less because of higher fishing costs and a low per pound price.

The August 31 report:

                               Quota          Landed

General Category  908.3 MT    60.6 MT- 328 fish

Harpoon                  90.0             21.2

Longline                 

      North                 116.3           14.1

      South                  72.1              4.6

Purse Seine              530.0         146.0

US Quota             1,773.0          246.9

The US Commercial bluefin fishermen catch is less than 15% of their quota by August 31. The quota allocation for this time period was 60% of the General Category quota. Some blamed global warming and the higher ocean temperatures north of Cape Cod. Others have blamed the massive catches of herring baitfish by mid-water trawl boats is a major reason for the low landings. The European and African countries bluefin landings have exceeded ICCAT’s scientists’ sustainable quota limits for 20 years. How long can our conserved bluefin survive other countries slaughter?

 Whatever the reason, there has been a major change in this fishery this year and last year as well. The Gulf of Mexico had very low longline landings at the exact same time that Mexico reported record bluefin tuna sales during the bluefin spring spawning time. This despite a major reported increased fishing effort by US longliners in the US Bluefin tuna spawning area. Naturally, no one wants to believe that US fishermen would sell their bluefin to Mexico buyers. Why Not? US effort is proven, so why are US landings so low?

 The US longline sword fishermen are also having a difficult time making a profit. Part of their landings drop is due to low prices received for their catch. Massive swordfish imports have kept commercial market swordfish prices low. It is now difficult for US commercial fishermen to make a profitable swordfish trip because of the low dockside price they are getting.

 Are those who supported international free trade agreements taking notice? Their support for free international trade is having major and terrible negative impact on all US businesses, not just steel and US manufacturing businesses.

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