Highly Migratory Species Report

NMFS HMS rules for this season are one school bluefin tuna 27”to 47” and two large school / small medium bluefin 47” to 73” . The good news is there is no closed season this year. The fishery will remain open the entire summer enabling anglers to keep a small bluefin, if they find one.

NMFS-HMS division is proposing a Large Coastal Shark (LCS) management plan that eliminates recreational landings of several important recreational LCS species. Then they approve commercial landing and sale of these same species. Their cover is by eliminating recreational landings of hard to identify species the species will recover. It is all a sham. NMFS is mandating identifying sessions for both commercial fishermen and dealers to identify these very same species.

The scientific literature has many articles written by world class fishery biologists who clearly state that no directed commercial shark fishery has ever been sustainable. Yet, NMFS in their infinite wisdom has proposed a shark plan that mandates that NMFS will accomplish this impossible objective. How can they legally under the Magnuson Act eliminate the recreational part of the fishery and continue a directed commercial shark fishery which is unsustainable?

NMFS proposes a limited commercial fishery to continue on the LCS fishery. The commercial LCS fisheries very existence makes LCS shark recovery clearly impossible. They hide their nonsense with recovery estimates of the key species. Sandbar sharks with their recovery estimate for Sandbar shark is 70 years. Their recovery plan for the Dusky shark, which is most overfished, has a 9% chance of recovery in 100 years and only a 90% chance in 400 years under this NMFS-HMS proposal. How can they legally propose a shark management plan that takes 400 years to accomplish their objective?

But the final absolutely impossible proposal is their intent to permit commercial landings of 30% of the LCS species while discarding 70% of the sharks they expect to recover. Does this not make this plan an insane NMFS proposal? How can commercials discard 70% of their catch and still expect the Sandbar and Dusky sharks to recover? If this plan is not illegal and absurd then all fish management plans are a farce.

NMFS proposes to all the sale of LCS shark species meat other than sandbar that currently has a very limited or no US market for the shark meat! The selling price of these non-sandbar shark species will not and cannot support a directed fishery.

Finally, NMFS proposes an experimental scientific sandbar shark fishery to measure this shark’s recovery. The amount proposed is 116.8 MT per year. This amount of sandbar sharks is greater than recreational estimated landings of this same species. But NMFS-HMS division proposes to allow a commercial directed fishery to exist and at the same time eliminate the recreationals?

NMFS estimates that 143 directed commercial shark permit holders earn $26,000 per vessel per year from the sale of LCS products. In total this is $3,900,000 of earnings per year. Given the total number of NMFS personnel required to run this management plan, their total dollar cost exceeds the dockside landing value by a major amount. How can they allow a commercial plan to exist when the management cost exceeds its value? Why not give the $26,000 each directed shark fisherman has earned to the shark fisherman and eliminate NFMS cost of shark management? The US spends billions per year to support farmers. Why not pay commercial shark fishermen not to fish? In addition to saving taxpayer money, there would be a reasonable chance of the sharks recovering. Finally, the huge economic value difference between recreation sharking and commercial sharking is not considered. Why not?

NMFS’s proposed shark plan is not only scientifically invalid but impossible by any standard.

Finally, and possibly most importantly, the US EEZ ecosystem is being totally changed by the elimination of LCS sharks. Skates and Rays are becoming so numerous in our bays and near ocean waters that they are eliminating the clams and oysters from our bays. In addition, when not finding enough clams or mussels to eat the sharks and rays are targeting blueclaw crabs. But they have to eat something. Our near ocean and bay ecosystem will totally change without the presence of LCS sharks in quantity.

An important recreational southern shark species in the south Atlantic and Gulf of Mexico is the black tip shark species. NMFS proposes to eliminate all recreational blacktip landings even though this species is identified by NMFS as not overfished. Their reasoning is a spinner shark that is in trouble could be misidentified by recreationals, therefore recreational anglers must be eliminated from this fishery.

Understand spinner sharks and blacktip sharks are so totally different that this proposal is pure nonsense.

Many involved in fishery management have often criticized NMFS-HMS fishery management choices. No part of NMFS management has received more criticism than NMFS’s HMS Division. Most other fish management plans have evolved from either the 8 management councils or state units like the Atlantic and Gulf state management groups. Anglers do not support many management programs because of their clear commercial bias. But at least there is some dialogue and the final plans are frequently modified to provide the final management plan with a degree of angler fairness.

Please call or write NMFS HMS division in Silver Springs, MD and voice your objection or you will be eliminated from one more fishery. But worse there is ZERO chance that the LCS shark fishery will recover ever.