(from Jersey Coast Anglers Association December 1999 Newsletter)A series of official actions by NMFS on HMS are confusing at best. These actions appear to be written to impose unacceptable fees and disputed future low quotas on recreationals at worst. NMFS has requested comments that would permit coastal gill-netters to decimate the inshore HMS fisheries by issuing "Exempted Fishing Permits". I will limit my comments to a short paragraph on each item; new fees, disputed low quota number, exempted fishing permits and the longline buyout bill.
NOAA Fisheries has contracted with AppNET, Inc. to issue Atlantic Tunas permits for the 2000-fishing season. HMS permits will now be available immediately over the Internet. The fee for the permits will now be $25.00 or $7.00 higher or 40% higher than the old fee of $18.00. The boats covered have rapidly grown with an huge increase from the original Bluefin tuna permit Maine to Virginia to a HMS permit which covers Maine to Texas. As of October 20, 1999 there were 13,157 anglers, 2,460 charterboats and 6,822 General category, 422 Incidental/longline permits and 48 Harpoon permit issued. All permit holders subject to a fee that goes entirely to AppNet Inc.
13,157 + 2,460 + 6822 + 422 + 48 = 22,909 x $25. = $572,725. This seems like an overpayment for a permit that was issued free by NMFS only 4 years ago.
The End of The Yellowfin Tuna Era ?
Disputed low quota number reported to ICCAT
A recent a last minute NMFS action reported FINAL US Yellowfin Tuna landing number to ICCAT. These revised but disputed low numbers were made public just one day before the US fall ICCAT advisors meeting. The low recreational numbers contained in this report will eliminate anglers from full participation in Yellowfin tuna fishery. NMFS FINAL US Numbers were followed immediately by an unprecedented Federal Registry Notice which said in part: "NMFS is publishing final statistics on the level of US recreational and commercial landings of Yellowfin tuna in metric tons since 1981. Preliminary statistics were published in March 1996 and NMFS received considerable public comment NMFS considers these historical records as the best data available at this time. NMFS, therefore does not intend to consider further revisions to these records unless, new verifiable data become available". .
There has been six years of heated discussion with NMFS on their LOW numbers, especially their LPS numbers for Maine to Virginia. Six years to resolve low ICCAT numbers resulted in meaningless revisions. The recreational landings being reported are 25% to 300% lower than DOCUMENTED landings from NMFS own Marine Recreational Fishery Statistical Survey (MRFSS). NMFS-MRFSS division counts angler landings of fluke, stripers, bluefish, black sea bass, scup, Spanish mackerel, king mackerel plus others species for ALL other management plans.
How can MRFSS be good enough for 14 other management plans and be totally dismissed in the LPS survey area? Has NMFS deliberately under stated recreational landings to support an ultimate goal of destroying the huge US Yellowfin fishing fleet?
Why else would they go out of their way to under report any category for ICCAT quotas?
Before answering these questions, consider NMFS moves made to date in estimating actual US recreational YFT landings.
In 1993 NMFS announced that they were going to regulate anglers Yellowfin landings to comply with ICCAT's mandate to "limit Yellowfin tuna effort to the 1992 level". NMFS planned to use quotas to control the US "effort". They first proposed an angler quota of 305 MT and included the commercial troll-landing category of 104 MT believed sold by anglers in the total. Commercial Yellowfin tun landings were also under reported but nowhere near the magnitude of the under counted angler numbers.
This announcement set off firestorms of protest by anglers and commercial fishermen. The proposed 305-mt quota would have been fully used in 1994 by a single New Jersey inlet! Manasquan inlet tuna fishermen in 1994 estimated they had landed over 500 mt. of Yellowfin tuna. The 409 mt. quota proposed by NMFS was for ALL US anglers between Maine and Texas, not just New Jersey. As a result of the protests, NMFS expanded their LPS Bluefin tuna coverage to include the full recreational tuna season. The LPS data before 1994 only counted those Yellowfin tuna landed during the Bluefin season. As a result of this major LPS change, angler 's LPS reported by Yellowfin tuna landings soared to 4,522 mt. in 1994, 4,157 mt. in 1995 and 4,498 mt. in 1996. These are all OVER 10 times or 1,000% higher than the original 409-mt proposal. NMFS LPS changes makes all years prior to 1994 invalid in the number or tons of Yellowfin Tuna landed by anglers.
However 1992-year is still being used as the ICCAT base year from which "the fishing effort should not be increased". NMFS has restated their ICCAT 1992 landings to 957 mt. over Twice the Tonnage of the original 409 mt. proposal. However 957 mt. is less than 25% of NMFS's angler YFT landings being counted by the revised LPS system.
Many anglers believed from the outset that NMFS intended to eliminate recreational future participation in YFT by under reported anglers' actual landings. Based on NMFS ICCAT reported US numbers future quotas would be impossible to manage without a very short fishing season and absurd tiny boat limits. This double barreled combination of a short season and tiny bag limits would destroy a huge recreational industry and the support system YFT anglers spending created. This would be a devastating economic blow to the Mid-Atlantic coastal state's economies.
Exempted Fishing Permit's (EFP)
NMFS Federal Register notice dated November 4th said: "NMFS is seeking public comment on the potential impacts of using EFPS for the purpose of landing Atlantic tunas (other than bluefin tuna) incidentally caught in the coastal driftnet fishery. The two EFP requests received to date specifically request authorization to retain skipjack tuna. Based on 1997 landings NMFS estimates that up to 20 vessels may request an EFP for the retention of skipjack tuna and may retain up to a total of 32,000 lbs. or 14.5 Mt of skipjack . It is probable that such incidental catch of skipjack can not be practically avoided and would otherwise be discarded dead." Written comments on NMFS consideration to issue such EFP's must be received before December 6, 1999. Send comments to: Rebecca Lent, HMS Management Division F/SF1, NMFS
1315 East-West Highway, Silver Springs MD, 20910."
The offshore drift net fishery was closed because of a big kill of mammals, which was illegal under the Mammal Protection Act. Additionally a large number of sea turtles were
killed which was contrary to the Endangered Species Act. Allowing coastal driftnets would likely have an even higher incidental catch of these mammals, turtles and birds.
Atlantic Bonito are a key recreational species. Allowing new commercial nets in a closed fishery would cause direct gear conflicts between recreational anglers and commercial driftnets and should be avoided. There are no conservation restrictions stated in the federal register notice. No limits are place on net size, length or geographic area and as a result ocean driftnets would again become legal. Since Atlantic bonito are one of the HMS species named by NMFS in the Tuna management plan, it would appear that the Atlantic Bonito fishery must be closed under the HMS rules, not expanded.
As always, if you do not write and state your strong opposition, NMFS will move ahead.
Thanks for taking the time to write a letter to NMFS on this issue.
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