(from Jersey Coast Anglers Association June 1999 Newsletter)
John Koegler's Report on Yellowfin Rules
Shark Plan Shortchanges Anglers and Conservation -Al Ristori
The National Marine Fisheries Services (NMFS) Highly Migratory Species Division with the publication of their HMS management plan for Swordfish, Sharks and Tunas has rejected the goals set for them in The Magnuson/Stevens Sustainable Fishery Act. Key provisions of this act were to reduce bycatch, halt overfishing and rebuild overfished fisheries in as short a time as possible but not to exceed ten years, Yet, NMFS has disregarded these mandated provisions of the Act.
This plans commercial bias is so undeniable that it is also illegal under Magnusons National Standards guidelines. NMFS has written this plan to shift the impact of any stock rebuilding from commercial fishers, primarily longliners, to the recreational fishing industry. The statistical data provided in the plan proves the stock damage was entirely due to excessive commercial exploitation Commercial overfishing was uncontrolled by weak, ineffective and unenforced rules, This has resulted in billfish and HMS species being commercially overfished. Yet the plan addresses none of the MANDATED bycatch and discard issues caused by commercials! As a result the needed rules do not exist.
NMFSs HMS plan will limit recreational anglers ONLY to a 3 yellowfin tuna (YFT) bag limit per person per trip This will reduce recreational landing totals before any YFT quota is required. Based on previous plans, the 3 yellowfin angler limit will become the base from which future regulations will ratchet down. This will repeat NMFSs past history where they eliminated recreational anglers from the bluefin tuna fishery by constantly tightening the regulations. .Yellowfin tuna have not been declared overfished by anyone, and making the rule apply only to recreational anglers and not commercials is biased and also illegal.
US anglers already lead the world in yellowfin tuna conservation under current rules. The ICCAT minimum size is 3.2 kg. US minimum size was increased to 6.4 kg to make the rule consistent with the US bluefin tuna size limit and avoid identification mistakes. A 6.4-kg minimum is 100% greater than ICCAT requires and yet NMFS wants more! Anglers already gave more when NMFS again increased the minimum size from 6.4 kg. or about 24 inches to 27 inches to make sure the standard was above minimum. In effect the US minimum size is 7 kg. and far above the international required minimum size. Why is this not enough angler conservation for NMFS?
Recent ICCAT data reports more than 50% of the Atlantics yellowfin tuna are baby yellowfin less than the mandated 3.2 kg minimum. At a reported 55,000 Mt, this is one huge amount of baby tuna, Assuming they are all 3.2 kg or 7 pounds, then this totals over 17,000,000 baby yellowfin tuna. All ICCAT parties agreed to the 3.2-kg. minimum when ICCAT was formed 22 years ago. The minimum size restriction was just reaffirmed by ICCAT. However, the other ICCAT members ignore the legal minimum size.
ICCATs rules have an allowance for undersized yellowfin but it is 15 % of the boated fish by number, not weight, This reduces the estimated legal small fish allowance to less than 5% by weight. Is this occurring because the US ICCAT delegates have not required compliance from other ICCAT members? Why increase limits when no compliance exists. It is clearly wrong and illegal to require only the US recreational fishing industry to conserve yellowfin, while at the same time, our government allows other ICCAT nations to slaughter 17,000,000 baby yellowfin tuna.
In 1996 New Jersey recreational anglers spent $747,000,000 on saltwater fishing. Those fishermen seeking offshore HMS species, primarily yellowfin tuna, spent 21 % of this huge amount or $156,000,000. In the US area affected by these new regulations offshore spending totals exceed 1.9 billion dollars.
To show how useless the proposed rules are, a simple hook comparison explains the point. On a calm August weekend 1,000 recreational, charterboats and headboats target tuna on a Saturday night from Massachusetts to Texas. Each boat fishes 3 lines. Rarely are more lines fished because they get tangled. In this vast area, just SIX longline boats set 20 miles of line each (some set 40 miles) with 500 baited hooks. Some longliners make two 20-mile sets which soak for 24 hours -- 1,000 recreational anglers and just six longliners have set the same number of hooks, 3,000! Yet, HMS economic data offered in the HMS plan, -"part 11"- reports equal dollar effects on national and state economics! How can this be? NMFS says 1,000 recreational boats have the same economic effects as 6 longline boats!
Clearly, this is absurd! The economic effects of denying the 11,000 recreational tuna permit holders plus another 2,000 charterboats access to the tuna is a huge amount of money estimated at more than 1.9 billion dollars. NMFS reports that the 1996 value of all NJ commercial HMS landings was $3,202,000.
New Jersey fishers paid for more tuna permits," 2,223 private boats plus 399 charterboats" than any other state. The economic effects of these new rules will devastate a huge industry. Many jobs will be lost and businesses closed at marinas, engine repair, and tackle shops as angler spending ends. The big boat manufacturers like Viking, Ocean, and Post will lose sales and downsize. Luhrs plus many smaller manufacturers who produce one to 10 boats per year each will increase the jobs lost. At least 3,000 NJ service jobs will end plus an additional 2,000 boat building jobs will be lost. Since no recovery of yellowfin stocks can result from the new rules, what is NMFS s objective or goal?
A review of NMFS recreational yellowfin landing numbers answers this question. NWFSs estimated 1997 angler landing numbers were originally 3,519 Mt, later revised upward to 4,800 Mt. Angler estimates supported by MRFSS data prove actual landings are two TIMES higher or 11,000 Mt. Consider the effect on 11,000 angler boats and 2, 000 charterboats which make 10 offshore trips a year. This is 130,000 trips taken a year. A management limit based on 4,800 Mt. is 10,582,080 pounds of tuna or 264,552 40-pound yellowfin tuna.
This is a limit of TWO Yellowfin tuna per trip per yearNot 3 fish per man per trip. Three fish per man is only the rule BEFORE regulations begin. Taking 130,000 trips at 2 fish per trip equals 260,000 tuna. Figuring 4,900 Mt in 10,582,080 pounds comes to 264,552 tuna weighing 40 pounds -- about 20 yellowfin per permitted boat per season!
How many charterboats or private anglers will buy or even keep an expensive offshore capable beat when faced with a yellowfin tuna limit? NMFSs absurd low angling catch numbers before international regulations even START, will eliminate angler participation. Any new rules will ravage the huge angler supported industry until NMFS corrects their current phony low numbers with an honest count. Nothing works if the beginning numbers are wrong by 100 to 200%.
That NMFS angler numbers represent a major undercount that was documented at the recent ICCAT advisors meeting. At this meeting NMFS announced angler numbers reported to ICCAT would be 4,800 Mt. A North Carolina fisherman stated his state could now document 3,000 Mt of yellowfin landed in North Carolina in that year. This is 60% of the entire East Coast, Gulf of Mexico, and Caribbean quota total of 4,200 Mt. If accepted this would require 18 states plus Puerto Rico and the Virgin Islands to share a tiny 1,800 Mt. quota. New York and New Jersey have years when they land over 1,000 Mt. each. How impossible will it be to allocate 1,800 Mt or 99,207 40-pound tuna between 18 states and 11,000 recreational boats? That means 11,000 recreational boats must share 9.018 yellowfin tuna per boat per season.
Clearly this is NMFSs planned bluefin tuna management fiasco all over again! Since NMFS angler landing numbers are clearly wrong, anglers will quickly be reduced to two yellowfin per boat per trip in the next round of regulations. The three yellowfin proposal is just the beginning of angler elimination by NMFS dishonest regulations.
A single paragraph from Ocean Wildlife Campaigns 40-page HMS comment letter sums it up best. "The international issue has for years been used by NMFS as an excuse to minimize or avoid altogether needed action to rebuild and protect HMS. The result is a plan that fails to achieve rebuilding and bycatch reductions mandates within the Magnuson- Stevens Act or to meet the objectives of the draft plan itself, while highlighting a serious credibility gap between NMFSs stated plan and its action," Will you sit and watch as our offshore fisheries are sacrificed to NMFS/HMS divisions commercial fishing bias and proposed commercial "status quo"? NMFS intent of angler elimination from their traditional and historic fisheries has never been so clear and so undisguised. "See you in court" is the only choice anglers and the huge industry their spending supports has. Nothing else can or will save our valuable offshore fisheries from NMFS resource theft.
If this is the best NMFS/HMS division can do for our precious offshore PUBLIC fisheries resources, then this division has no business in fisheries management.
The shark portion of the National Marine Fisheries Service (NMFS) Highly Migratory Species Management Plan demonstrates once again that NMFS has little interest in conservation when it interferes with the desires of special interests, but will not hesitate to destroy traditional recreational fisheries in order to achieve meaningless reductions in mortality.
Despite all the talk about conservation, NMFS pointedly refuses to do anything about the shortfin mako shark resource, which has been declining rapidly for years. Every year we plead with NMFS to lower or eliminate the pelagic shark quota, but the agency completely ignores the decline, which has been obvious for years and watches yet another species go downhill before their eyes. Perhaps Im being too harshafter all they did lower the recreational shark quota this year by 50% which means that all of you out there who have been landing two makos per day the last few years are really going to be hurting. That regulation may save SEVERAL makos this year. In addition theres a 4 ½-foot minimum length, though few anglers keep makos that small any longer. Of course that minimum length doesnt apply to longliners, who continue to enjoy a pelagic quota too big for them to fill with the available resource even while killing the tiniest makos.
What is the reasoning for apply the 4 ½-foot minimum to anglers but not longliners? It seems there is little shark mortality on rod and reel, but a great deal on longlines. Yet, NMFS has imposed the 4 ½-foot minimum on catches of large coastal sharks for both commercial and recreational fishermen. If reasoning has anything at all to do with anything NMFS does, how can they justify requiring large coastal shark longliners to keep only those over 4 ½ feet while not caring how many baby makos are dumped in longliner holds?
Its hardly surprising that the agency which capitulated to longliners on the closed juvenile swordfish areas and most of the June area closure to prevent giant bluefin tuna by-catch also provided them with lots of gifts in the shark area. Topping the list was the underhanded provision of a blue shark landing quota, which was never brought up for discussion at the public hearings.
Longliners had sought to remove blue sharks from the pelagic shark quota years ago in order not to fill that quota with a low-priced species and possibly shut off fishing for valuable makos, threshers and porbeagles. Sportsmen wouldnt let them get away with creating even more damage than theyre already doing by discarding dead by-catch, so that low-priced shark market wasnt developed. The original proposal by NMFS was to make blue sharks a prohibited species while allowing longliners to kill 545 metric tons before anything would be deducted from their pelagic shark quota.
Sportsmen objected to the prohibited status, even though they rarely keep blue sharks except in the few tournaments which still permit them, as not being necessary for the one shark which hasnt been too badly depleted so far. Yet, instead of simply allowing the blue to be eligible for the one shark anglers can retain, NMFS went from prohibition to allowing longliners to market their dead discard quota. That means theyll be able to target blues without losing the ability to pound more nails in the makos coffin.
The only concession NMFS made to anglers was allowing one large coastal shark of at least 4 ½ feet to count as the one per boat limit as well as pelagic sharks. That modified their previous intention to shut angling off altogether for large coastals while permitting the commercial fishery responsible for the devastation of those fish during the last decade to continue with a healthy quota. Even NMFS had to realize that such an indefensible action would never stand up in court, so they made the slightest of concessions while continuing to ignore the need to end all directed commercial fishing of large coastals before the various populations crash altogether.
There are so many fine points buried in the regulations that it will take some time for us to sort out all the goodies NMFS has provided for commercial sharkers while doing their best to destroy whats left of a once vibrant sportfishery. However, you can be sure that if the items mentioned above arent fought the long-term prospects for sharks will be grim indeed.