Highly Migratory Species Report

Anglers have often disagreed with NMFS-HMS division management plans. All their plans have been designed to limit recreational landings and yet continue the commercial fishery without limits or controls. Of all their plans none is more commercially biased than their new proposed shark plan. In fact, it is so biased that it appears illegal if the Magnuson’s Fishery Management Act’s “National Standards” are the standard used.

Here are the plans proposed key items:

Close sandbar shark landings to recreational and commercial fishing. Sandbar sharks are overfished. The plan ends recreational sandbar landings. But a commercial research sandbar fishery of 116.6 MT dressed weight (dw) will continue. NMFS states this is needed to assess the recovery of sandbar sharks. Note that recreational landings from 2002 to 2005 are estimated to be less than the proposed research landings per year.

Part of the reason recreationals are eliminated is they must know the difference between Dusky sharks and Sandbars which are very similar. Duskys are approaching a threatened population status. Since recreational could land a Dusky shark by mistake NMFS-HMS believes they must eliminate recreational landings of Sandbars to save the small Dusky population. At the same time commercial fishermen and dealers are mandated to attend a NMFS class where they are taught to identify all shark species.

Continue the non-sandbar commercial shark fishery at a high landing level of 541.2 MT dw. The problem with the continued longline bottom shark fishery is their sandbar/dusky bycatch will be 70% of the catch. How can this fishery ever recover if the sandbar/dusky bycatch discards represent 70% of the catch and is discarded dead?

NMFS-HMS states that this continued fishery will only increase sandbar discards from 9.6 MT to 13.1 MT.

Since 70% of the catch is Sandbar sharks and this species will now be discarded, such a small reduction in discards is mathematically impossible.

1. NMFS says their new plan will reduce the discard of non-sandbar sharks from 153.3 MT to 56.6 MT. This is unlikely because these discards represent shark species that have little or no commercial meat value at retail. Most of these sharks have either poor meat quality or strong taste making them unlikely to have a demand at retail.
   
2. NMFS-HMS also states their plan will reduce the accidental landings of the severally overfished Dusky shark from 33.2 MT to 9.2 MT. Given that there is NO proposed reduction of commercial longline fishing effort, this is totally unachievable.
   
3. Close recreational Blacktip shark fishery in S. Atlantic and Gulf of Mexico while allowing the commercial fishery to continue. The Blacktip shark is not overfished at this time. Eliminating the recreational fishery permits a larger commercial landing of this species which has both retail acceptance and sale value.
   
4. NMFS in their plan now names which shark species anglers will be permitted to land in the future. They are lemon, nurse, scalloped, smooth and great hammerhead, tiger, blue, common thresher, oceanic whitetip and short fin mako. In addition, one bonehead and one Atlantic sharpnose shark can be retained per trip.
   

Many world-class fishery biologists have written peer reviewed articles about direct commercial shark fishing. They clearly state that NO directed commercial shark fishery can ever be sustainable. Ignoring this accepted scientific fact, NMFS has proposed a shark plan where NMFS will accomplish this known to be impossible objective.

Scientists know and NMFS is ignoring the fact that the reason NO commercial shark fishery can EVER be sustainable, as required by the Magnuson Act, is their biology. Sharks live a long time and become sexually mature only after many years. Their reproduction is by live shark births which makes recovery from directed commercial fishing unattainable.

If you do not desire to be eliminated and then strictly limited to what shark species you will be permitted to land, you must reply to the NMFS-HMS division proposed shark plan immediately. You can download their 9 page Federal Registry notice from the HMS website under new news.

Please write, e-mail or fax the NMFS HMS Division and state your strong objections to any shark management plan that allows a directed commercial shark fishery to exist and eliminates recreational landings. The deadline for comments is October 10, 2007.

Send comments labeled “Comments on Shark Amendment 2” to: