By John Koegler

(from Jersey Coast Anglers Association - December 1996 Newspaper)

During November, the proposed 1997 Atlantic Tuna rules will be published by NMFS. December will see scoping meetings to give us time to comment and voice opinions on the NMFS proposals. Final rules are scheduled to be published by January 1, 1997, which is a significant departure from previous years when final rules were not published before June and scoping meetings were held in April or May.

This year's ICCAT meeting in Madrid will consider additional regulations for yellowfin and bigeye tunas. The United States lands a very minor percentage of these species when compare with worldwide harvest figures. The problem we are dealing with right now is that the U. S. harvest statistics that have been sent to ICCAT for the past ten years are totally inaccurate and unacceptable for both the recreational and commercial sectors, alike.

The present ICCAT advisory on yellowfin establishes 1992 as a sort of harvest "base year" at which "fishing effort" is to be capped and then, eventually reduced. The problem with this is the term "fishing effort" means different things to different ICCAT member nations. NMFS chose to use landing data for 1992 to establish a U. S. quota base as their determination of "fishing effort," from which international and domestic quotas will be determined. Other countries use the numbers of boats in the fishery, number of hooks set, days at sea or tonnage harvested to define their level of "fishing effort." With misunderstandings like these, it's no wonder international management's track record stinks.

During 1991, Congress, bending to the intense commercial lobbying pressure placed upon it since 1975, finally allowed domestic managers to regulate tuna fishing in the U.S. EEZ. The job of managing the stocks was assigned to the Department of Commerce, which delegated the job to NMFS, creating a new division called Highly Migratory Species (HMS) management. However, the funds to mount the management task were not allocated until the 1992-93 fiscal year. During this lapse between assignment of the duties and providing the money to do it, recreational tuna statistics gathering that was abandoned by many states, expecting NMFS to perform these functions. As a result, U. S. recreational yellowfin (and other tuna) harvest estimates were grossly under-reported during the 1992 fishing year. Only 949 MT were counted by NMFS Large Pelagic Survey (LPS) for the rod and reel category, plus 104 MT listed as sold by rod and reel anglers under the commercial troll category.

The Marine Recreational Fishing Statistical Survey (MRFSS) a harvest survey conducted by the coastal states in conjunction with NMFS using incomplete data, counted more yellowfin by orders of magnitude, than the LPS and it only includes a portion of the yellowfin harvesting states for 1992. In fact, 1992 represented the lowest harvest total for yellowfin in the current ten year MRFSS data time series. The total number of yellowfin harvested in the northeastern states that year according to MRFSS data was only 62,665, a fraction of the 10 year average of 292,831 yellowfin and only 12% of the peak harvest years of 19986 when 520,167 were caught and 1994 when 540,341 were harvested. If you look at these figures in another way, 1992 was 8.62 times lower in harvest than the peak years or 862% lower!

Obviously, any yellowfin allocation plan that uses 1992 as the base year will not only project an incomplete picture of the actual harvest, but it will do irreparable damage to the recreational fishery. Any regulation of recreational harvest can not be based on an anomaly year like 1992 when NMFS record keeping is incomplete and it is so obvious by the shear difference between the 1992 figures and other years in the 10 year data set. Please note that whatever base harvest figures is used to establish a "fishing effort" cap for recreational fishermen will then be reduced as management ratchets down on mortality to reduce effort.

Conversely, the U.S. commercial yellowfin tuna efforts and catches in 1992 represent their highest catch levels in the most recent 10 year period and landings were higher everywhere but in the Gulf of Mexico, where yellowfin are over-fished and commercial catches are under-reported. This big increase in commercial effort is obvious when compared to their 1990 and 1991 fishing data. New northeast entrants into the commercial fishery included pair-trawls and increased effort by purse seiners, which increased commercial harvest during 1991 and 1992. Could it be that this big increase in commercial effort and harvest was in anticipation of new international regulations? Can anyone prove otherwise? Those not familiar with NMFS-HMS management often wonder why recreational interests are so disillusioned and bitter over this agencies commercially-biased actions and management style. It is so clearly evident that NMFS continues to deny and ignore meaningful reform for recreational interests in HMF fisheries that you'd have to be blind to miss it. As far as NMFS-HMS is concerned, the only tuna with value is one landed commercially dead on the dock. Those taken by recreational interests apparently have no value in their eyes, even though they support a multi-billion dollar fishing industry.

If recreational fishermen fail to get an honest count for yellowfin participation and harvest, the marine trades industry along the East Coast and Gulf of Mexico states will suffer big time, as will the tackle industry, charter boat industry and tourism. Yellowfin tuna represent the backbone of the recreational offshore fishing fleet and their efforts, not billfish, not any other species.

What is noticeable is the lack of concern expressed at the ICCAT advisors meeting or other public meetings by those who stand to be most negatively affected financially by the loss of this fishery, companies in the marine, tackle, coastal tourism and charter fishing industries. JCAA can not win a tuna battle alone, nor in concert with a few other regional advocacy groups. It must be a coordinated, industry backed initiative! The dollars spent in the northeast alone to catch tuna and other pelagic species is estimated at over a $1/2 billion annually. The total reported value of the commercial northeast yellowfin landings is under $10 million annually. To our fisheries managers, this should be a "no brainer"! How can you value a $10 million dollar industry above the needs of a $1/2 billion dollar industry and call your cabinet agency the Department of Commerce. Commerce apparently has nothing to do with it, but back-room politics sure does. If your business depends or benefits in part from a viable recreational offshore fishery, you better wake up and smell the rotten fish. If we experience draconian restrictions like licensing of private recreational boats, closed seasons and bag limits, you will lose business big time! Just remember, concern for the health of the recreational fishing industry has never been a hallmark of NMFS-HMS management, or any other management plan for that matter. Can your business or industry afford another major downturn in recreational fishing participation? When all is said and done, realized that NO FISH = NO BUSINESS!

JCAA Comments Presented at the November 6, 1996 Meeting of U.S. ICCAT ADVISORS

ICCAT's Standing Committee on Research & Statistics (SCRS) reports on the landings of bluefin, swordfish and other Highly Migratory Species (HMS) should cause anyone who understands this fishery in U.S. waters cause to seriously question the past direction of U.S. policies regarding the management of all HMS fisheries.

Clearly, only the United States has made any meaningful attempt to control it's fishermen's landings of bluefin and swordfish, and is honestly addressing problems with other over-harvested HMS fisheries. ICCAT mandated an end to overfishing of bluefin tuna and instituted minimum size restrictions for all ICCAT member nations 20 years ago. These mandates are being totally ignored by most ICCAT member nations, with the exception of the United States. The non-compliance of most ICCAT nations with the original intent and management objects put in place to protect this fishery appear to be total among other member nations. Compliance of non-member nations is ridiculous and makes the management objects of this treat organization a farce! Some member nation's self-reported HMS exports exceed their ICCAT allocations. Many of these HMS species exports are imported into the United States, yet the State Department and Commerce turn the other way. How can there be any recovery of any HMS fishery if no one but the United States follows the ICCAT management regulations. How can we possibly welcome ICCAT management of additional tuna species, especially yellowfin and bigeye tunas, when it appears assured that no member nations will comply with them.

Last week, the Mid-Atlantic Fishery Management Council passed three resolutions, which better represent the position of many in the mid-Atlantic states than anything I could say.

  1. I move we recommend that the Council send a letter to Rollie Schmitten with copies to Bill Dr. Bill Hogarth, Brad Brown and Will Martin expressing our acute concern regarding U.S. catch statistics for yellowfin, bigeye and albacore tunas. The recently released figures, both recreational and commercial, in our judgment, are substantially below the levels of actual catches and need to be corrected before ICCAT develops national quotas or quota shares for these species. (Jensen/Weiss and carried with RA abstaining)
  2. I move the Council recommend that no further ICCAT quota reductions be accepted by the U.S. until other nations' compliance with existing ICCAT mandates are assured. (Jensen/Rodes and carried with RA abstaining.)
  3. I move that scientific monitoring to adequately gauge stock size, reproductive success, and growth at age cannot be accomplished without the harvest of small bluefin tuna. The number of small fish presently permitted to be harvested in the western Atlantic is limited to only those fish caught by U.S. rod and reel fishermen, since Canada and Japan do not target these fish. The Council urges our ICCAT negotiating team to explore possible mechanisms to permit a larger sample of these fish to be harvested by U.S. fishermen. (Caputi/DeLernia and carried - 7 yes, 2 no, with RA, Colvin, Weiss, Bryson abstaining)

Finally, the "Two Stock" theory of bluefin migrations and spawning stocks must be reconsidered. Today, and at this same annual advisors meeting two years ago, the participants were shown the plotted bluefin tuna landings by Japanese longliners that move across the Atlantic month by month from their November departure from the U.S. Grand Banks to their arrival off the Straights of Gibralter in May. In light of this data, the one stock concept must be questioned, especially when we consider the huge 1994 and 1995 landings in the Mediterranean and Eastern Atlantic.

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