TELL NOAA FISHERIES NOT TO WEAKEN BLUEFIN TUNA REGULATIONS

Situation 
Western Atlantic bluefin tuna are severely depleted and need your help. NOAA Fisheries may eliminate proven conservation measures that are reducing bluefin bycatch and waste on U.S. pelagic longlines.  Specifically, NOAA Fisheries is considering modifying the use of weak hooks and existing time/area closures that prohibit pelagic longlining and protect western Atlantic bluefin tuna.  Tell NOAA fisheries to maintain these important protections.  Submit your comments online by Monday, May 1st, 2018. A sample letter is provided below.

Weak Hook Management
In 2011, NOAA Fisheries instituted a requirement for longline vessels in the Gulf of Mexico to use thinner-gauged weak hooks that straighten under the force of large, mature bluefin tuna to allow them to escape before dying. That change has reduced bluefin tuna dead discards in the Gulf of Mexico by nearly 75%. There was, however, a statistically insignificant increase catch of white marlin after their implementation, but it is currently uncertain whether this is the product of increasing white marlin abundance or the performance characteristics of weak hooks.   IGFA recommends that NOAA Fisheries require the use of weak hooks in the Gulf of Mexico from January through June to further reduce bluefin mortality and to also potentially reduce the catch of white marlin during summer months.

Gulf of Mexico
In 2014, western Atlantic bluefin scored a major victory when NOAA Fisheries issued Amendment 7 to the 2006 Consolidated HMS Fishery Management Plan.  In 2015, as part of Amendment 7, two gear restricted areas (GRAs) were implemented that prohibit pelagic longlining in 27,000 square miles of the Gulf of Mexico during peak bluefin spawning in April and May.  This closure has worked better than expected.  Average bluefin longline interactions have gone down by 82% and annual dead discards from the longline fleet in Gulf of Mexico have decreased from 69 mt in 2012 to just 7 mt in 2016.  Commercial fishermen can still fish in the closed areas for sustainable species such as yellowfin tuna and swordfish with greenstick and buoy gears that have minimal interaction with bluefin tuna.  In fact, the yellowfin tuna catch in 2016 was 38% higher than the 2006-2012 annual average, prior to Amendment 7. Weak hooks and GRAs are significantly reducing bluefin catch and mortality in the Gulf of Mexico and, most importantly, are protecting them in their only known major spawning area.  Modifying these closed areas less than four years after they were implemented makes no sense.

Northeastern Closed Area
The Northeastern Pelagic Longline Closed Area was implemented in 1999 and prohibits pelagic longlining during the month of June.  NOAA Fisheries is currently considering modifying the spatial and temporal extent of this closure.  However, IGFA recommends that no modifications be made that would allow longlines in this area in the absence of data via a rigorous scientific study, that includes fishing in the closed area in June, that would determine the impact of any proposed changes to this area.

ACT NOW!
The combination of time/area closures and use of weak hooks in the pelagic longline fleet has significantly reduced western Atlantic bluefin tuna mortality.  These protections are still warranted, as the population size of western Atlantic bluefin is estimated to be only half of what it was in 1974 when it was already declared depleted.  Tell NOAA fisheries not to reverse these important measures.  A sample comment letter is included below.  Submit your letter online by May 1st, 2018.

SAMPLE COMMENT LETTER

Mr. Craig Cockrell
HMS Management Division
Office of Sustainable Fisheries, F/SF1
National Marine Fisheries Service
1315 East-West Highway
Silver Spring, MD 20910

RE: Comments on NOAA-NMFS-2018-0035

Dear Mr. Cockrell:

Thank you for the opportunity to comment on the notice of intent (NOI) to prepare a draft environmental impact analysis on management of the Atlantic pelagic longline fishery and the accompanying Scoping Document: Issues and Options for Pelagic Longline Bluefin Tuna Area-Based and Weak Hook Management. I strongly urge NOAA Fisheries (1) to exclude any consideration of modifications to the Gulf of Mexico Gear Restricted Areas (GRAs) from any proposed rule, (2) to retain a January through June seasonal requirement for use of weak hooks on pelagic longline vessels and (3) to make no modifications to the Northeast Closed Area in the absence of data that can determine the impact of such modifications.

The options considered in the scoping document look specifically at management measures originally intended to reduce mortality of bluefin tuna, questioning whether the individual bluefin tuna quota (IBQ) program in place since 2015 affects the need for these measures.  While the IBQ program has been successful, the western population of Atlantic bluefin tuna remains severely depleted, at approximately half of its already depleted 1974 level

Modifications to the Northeast Closed Area should not be implemented until there is sufficient data to determine the impact of any proposed modifications. The Gulf of Mexico is the only known major spawning ground for western Atlantic bluefin tuna, and it is critical to continue to protect mature bluefin during their spawning season. The GRAs that resulted from Amendment 7 have greatly reduced bluefin tuna interactions with longlines in the Gulf of Mexico and this, combined with the use of weak hooks in the longline industry, has significantly reduced the amount of bluefin catch and dead discards.  The current international quota for western Atlantic bluefin tuna is predicted to lead to further population decline for the foreseeable future, making protection of these fish, particularly in their spawning grounds, even more important.