By John Koegler
(from Jersey Coast Anglers Association November1997Newsletter)
COMMENTS FOR U.S. ICCAT DELIGATION
Comments For National Marine Fisheries Service On Highly Migratory Issues
IMPORTANT MEETING- HIGHLY MIGRATORY SPECIES FALL SCOPING MEETING MONDAY OCTOBER 27 7 PM
The two following documents were presented at Tom River Hearing on October 1 conducted by NMFS and ICCAT Advisors. These documents were prepared by John Koegler and Gary Caputi.
COMMENTS FOR U.S. ICCAT DELIGATION
Topic: International Compliance
Retention of sublegal size tuna
Yellowfin tuna There was an international agreement brokered by ICCAT in 1975 that established a minimum size limit for this species of 3.2 kilograms. At present, compliance with this regulation has been non-existent by all signatories with the exception of the United States and Canada. It is currently estimated that in excess of 50% of the Atlantic catch is made up of fish under this minimum size limit. It is incumbent upon the United States delegation to take a leadership role in assuring this compliance issue is addressed and corrected.
Bigeye Tuna More recently, ICCAT reaffirmed that the same 3.2 minimum size applied to bigeye tuna, yet it is estimated that in excess of 70% of the harvest of Atlantic bigeye tuna is under the minimum size limit. All nations must comply with this most basic of conservation measures if any of the goals of stock protection are to be achieved.
Bluefin tuna Are the other nations complying with the 15% bycatch allowance of small school fish?
Of what value is it to restrict U.S. recreational fishermen to a unilateral 8% bycatch of small school fish in light of other contracting nations inability and unwillingness to live up to even a 15% bycatch allotment?
What is the contracting party compliance with ICCAT conservation management measures regarding:
- Western Atlantic Total Allowable Catch
- Catch reduction for Eastern Atlantic and Mediterranean
Comments For National Marine Fisheries Service On Highly Migratory Issues
1) Highly Migratory Species Advisory Panel:
NMFS proposes to manage bluefin, yellowfin, bigeye, longfin albacore, skipjack, sharks and swordfish with a single advisory panel. Due to the diverse natures of these species and the fisheries used to harvest them, and because the recreational fisheries for some of these species vary dramatically in regional participation and importance, we feel it is impossible to obtain the best advise from industry and users with a single advisory panel.
We feel that the combination of such diverse fisheries will only degrade public participation and force advisory panel members to try and represent fishermen that they do not have adequate knowledge of. The only acceptable option is to break up the advisory panel and the management plan for these species into smaller, more manageable units that encourage the maximum public participation and representation.
2) Bluefin Tuna Regulations:
a) Permits & Catch Reporting in the Angling Category: NMFS management of the 1997 Angling Category fishery was, once again, a total disaster. The implementation of a recreational tuna permit fee was supposed to answer the problems in obtaining accurate catch data. We understand that NMFS has now determined that there is only a 40% compliance with the reporting and therefore a multiplier must be incorporated in determining the angling category harvest. It appears that this is another failure and since it doesnt work, the permit fee should be waved in 1998.
In addition, a great number of recreational fishermen have not obtained permits through lack of knowledge of the existence of said permit. This leads to inaccurate reporting of actual catch.
Since the fishery in the New York Bight area has been closed prior to the fall season even beginning for the past several years, many fishermen have been assured that they will not have the opportunity to participate in the fishery and have therefore not purchased permits. This further reduces the perceived participation level when actually a far large number of recreational fishermen would like to participate.
b) Inadequate quota of small school fish: ICCAT permits the harvest of a 15% boycott of school fish by all contracting nations except the United States, which limits its fishermen to 8%. Since this portion of the fishery, which has the greatest potential to provide the scientific monitoring information the plan was designed to provide, is harvested by the Angling Category, it has a disproportionately negative effect on the recreational fishing community and industry. NMFS must return the full 15% of school fish to the Angling Category and stop the overharvest of the critically important and greatly reduced number of spawning fish.
a) We commend NMFS for implementing a 50% reduction in the harvest of large coastal species. We respectfully request the service immediately institute a similar reduction in the commercial quota for large pelagic sharks. A 50% reduction was already imposed on the recreational bag limit, but no corresponding measures have been taken on commercial harvest, which continues to decimate such important species as mako and thresher sharks.
b) We also understand there is growing economic pressure to fin blue sharks, a species that NMFS data indicates the dead longline discards easily exceed the entire commercial pelagic shark quota. We urge NMFS to renew its stance against the finning of any sharks and to step up enforcement accordingly. We also feel that future regulation of the dead discards of blue sharks will be necessary to avoid the continuing drop in stock of these sharks.
Traditional management by catch limits is not working for the overfished swordfish on either the domestic or international level. Small, sublegal and immature swordfish are captured and as part of the longline fishing process. Current size restrictions on landings result in even higher rates of dead discards with minimal conservation benefits. Atlantic swordfish can not be restored to their former abundance without management measures that strictly curtail catches of the most vulnerable species and age groups. Time and area closures are absolutely needed both domestically and internationally in known nursery areas and spawning grounds and other identified hot-spots where these severely overfished species are most vulnerable to capture by longline gear. The only other alternative to time and area closures would be the total ban of longline gear for the harvest of swordfish.
The list of options regarding recreational billfishing as presented in the "Issues & Options for the Management of Atlantic Billfish," a draft scoping document assembled by NMFS dated January 1997, takes aim at the user group that has already cleaned up its act while doing little to address the real problem, longline bycatch of these economically important species. Longlining is responsible for 90% of the dead billfish in the Atlantic, while recreational fishermen have made catch and release of billfish the watchword of the fishery. It is an insult to the recreational community to infer that recreational fishing for these species are responsible for the overfishing problem that currently exists when voluntary conservation has been eagerly accepted over the last ten years.
6) Yellowfin Tuna
NMFSs Yellowfin Tuna numbers proposed as United States landing Numbers in Metric Tons reported to ICCAT are underestimated for both recreational and commercial landing.
Place - Tomss River Holiday Inn (Exit 82 -East of the GSP) 290 East #37, Toms River NJ
NMFS may present two Highly Migratory Species Management plans plus their Environmental Impact Statements (EIS). One Plan and One EIS will cover Atlantic Blillfish ;Blue Marlin, White Marlin and Sailfish. The other plan will cover everything else? This new HMS plan will include Bluefin, and all other tunas, Yellowfin, Big-Eye, Long-fin & skipjack plus sharks and swordfish under ONE management plan for the first time! A proposal JCAA had strongly opposed.
NMFS draft plans for Billfish submitted to the Billfish Advisory Panel two weeks ago illustrates NMFS thinking on creating new regulations. NMFS in response to a Petition submitted by National Fisheries Institute (The commercial fishermans lobbing organization) proposed items that would limit recreational participation in offshore fishing. These Petition Items were included in a revised draft of the
Billfish management plan. Should NMFS do that when they had yet to act or make any comment about the petition? This is a entirely new approach by the commercial lobbyists to directly influence the creation of HMS regulations.
Other shocking items affecting future recreational fishing for Billfish that were part of the draft FMP submitted to the new Billfish Advisory Panel are;eliminate fishery advisory services, spotter airplanes & tournament awards over $100. Also proposed were no live bait nor chunking by recreationals. Rather than review a list of draft proposals that may not be part of final public version, I list previous NMFS proposals. Some of these deserve recognition for breaking new ground in economic theory and glaring theft of a recreational fishery by guile and deception. Special mention is needed because these are new concepts not taught by colleges or professionals nor an accepted system but belong under a Ripleys "Believe it or Not " classification.
1-NMFS-HMS divisions EIS valuation of recreational fishing.
NMFS HMS division makes an assumption; if recreational fishermen do not spend their money on fishing, there will be no economic impact. Tell the tens of thousands of businesses and those whose full time jobs depend on recreational spending that this spending has no economic impact. Even, if their jobs & businesses will disappear because of regulations? NMFS-HMS divisions absurd assumption is; there will be no national economic impact since recreationals will spend their money on something else, such as country clubs, golf or tennis. NMFSs makes NO such assumption about commercial fishermen making a living doing something else!
2-NMFS estimates the costs of recreational fishing listing only the consumables. This means, the cost of owning and buying a boat, insuring the boat, the yearly cost of dockage and needed maintain items are eliminated from the estimates of recreational costs. Consider estimating your cost of owning a car and leaving out the purchase cost, the insurance, plus garaging and maintenance items?
3-NMFS Large Pelagic Survey (LPS)
This survey is under intense fire from all sources because it does not accurately estimate the angler landings of Bluefin tuna. Ignoring the title Large Pelagic Survey, NMFS now claims the results of this survey are a "census". NMFS manipulates the raw data from LPS using a complex math formula. Understand, multiplying raw census data by anything ends the results census status.
No one but NMFS could ever believe LPS represents a census!
4- Yellowfin Tuna THEFT
NMFS in 1994 proposed quotas for Yellowfin tunas based on ICCATs recommendation to regulate "effective fishing effort based at 1992 levels". NMFS decided the only way to accomplish this in US waters was a quota based management plan.NMFS proposed 1992 rod & reel harvests levels were;
A- Original 1994 proposal --- 409 MT or 22, 903 tuna of 39.37 average weight
B- Revised 1996 proposal-1,053 MT or 58,965 tuna of 39.37 average weight.
C- MRFSS NE state estimate for 1994- 540,341 tuna
There is one hell of a difference between a quota based on the harvest of 58,965 fish and one based on 540,341 fish. This is a multiple difference of more than 9 Times! Is this the angler Bluefin tuna quota fiasco all over again???
5- NMFS system used to estimate angler 1992 harvests uses.
A- LPS data: North Carolina North to the Canada border
B- MRFS data: South Carolina South to the Mexican border
C- Non-Reporting area estimates are not made and left blank. Therefore the states of Texas reports two fish and the Caribbean area & Georgia report "Zero"
Marine Recreational Fishing Statistical Survey (MRFSS) is the system used by all councils, ASMFC and states for estimating recreational fishing effort in Stripers, Fluke, Bluefish, Sea Bass, Tog & Scup plus others. How can NMFS be permitted unchallenged to mix and match data sets when the supporting data from MRFSS is totally at odds with NMFSs LPS estimate? 540,341 MRFSS - 58,965 LPS = 491,376 fish difference. 491,376 fish is more than a difference of opinion!
6-NMFS issued 30,000 Atlantic tuna permits issued in 1996
Consider the proposed quotas from a different perspective. NMFS will issue over 30,000 angler, general category and charterboat tuna permits. NMFS revised higher rod & reel quota of 1,053 MT is 58,965 fish of 39.378 average weight. This is less than TWO Yellowfin tuna per permit holder per season !
You better find the time to attend the meeting on October 27. !!