CCA Comments on Atlantic HMS Amendment 7
CCA comments on Atlantic HMS Amendment 7
CCA appreciates the opportunity to present our concerns on certain preferred options set in Amendment 7. Given the complexity of the issues addressed in this amendment, we will provide a detailed set of comments prior to the December 31 deadline for public comments.
Our main objective with respect to bluefin tuna is to implement a recovery of the western stock to levels that will increase abundance and provide a sustainable fishery. We acknowledge the intricacies of international management under ICCAT, but are not persuaded by the argument that it is important to the U.S. to kill every bluefin that might be available under our share of the ICCAT assigned quota. Our impression is that this amendment is primarily more about re-distributing harvest than affording increased conservation to the species.
A. “Limited and conditional” access of pelagic longline (PLL) vessels to conservation zones presently closed to this gear.
In 2000 the NMFS established conservation areas closed to fishing by PLLs in an effort to reduce the bycatch and discard mortality of juvenile swordfish, sea turtles, marlins and sailfish. This action has proved to be one of the most successful conservation efforts by the NMFS in the context of highly migratory species (HMS). The agencies own analyses show that the closures dramatically reduced discards of blue marlin (by 62%); white marlin (60%) sailfish (67%) and undersized swordfish (57%) from pre-closure levels. Sea turtles also benefitted substantially by these closures.
The reductions in mortality have resulted in increased availability of billfish and swordfish in particular that has fueled the development of a robust recreational fishery for swordfish and record levels of catch-and-release sailfish and marlin catch per unit effort in the Atlantic and Gulf of Mexico. Reopening these areas to PLL fishing effort will put these conservation gains at risk and impose economic losses to the sport fishing community – losses that are not addressed in any socio-economic analyses in the DEIS that accompanies this amendment. We are opposed to any effort to reopen these areas to PLL gear.
B. New Pelagic Longline Gear Restricted Areas
We do not believe that establishing these small closures, which would restrict access to PLL gear in limited geographic areas, offer sufficient bycatch reductions to offset potential new losses afforded by allowing access by even a limited number of PLL vessels to currently closed areas.
We support a closure of the Gulf of Mexico west of 82 degrees to all PLL gear between March and August of each year. Such a closure would substantially reduce bluefin tuna discards in their critical Gulf of Mexico nursery grounds and would also provide significant reductions of dead discards to wahoo, dolphin-fish, billfishes, sea turtles and other marine life.
The proposed small Gulf of Mexico gear restricted area would reduce marlin and sailfish bycatch by 0-1%. The closure would reduce bluefin discards by only 3%. Compare this to a year-round closure of the Gulf to this gear which would allow for billfish discard reductions of 31%-50% by species and a 12% reduction in bluefin discards. Given that this full-year closure would force significant reductions in the retention of targeted swordfish and yellowfin tuna, we could support a 6-month closure as an alternative to maximize the discards reductions of non-target species while minimizing in a controlled fashion the reductions of legally targeted catch. The application of this 6-month closure would also create incentive for those commercial operations targeting swordfish and yellowfin tunas to develop expertise with greenstick, rod-and-reel, and selected buoy gears that would afford sustainable harvests of target species while substantially reducing bycatch mortality among the non-target species encountering the gear.
We would further suggest that a 6-month closure of the Gulf would afford sufficient bluefin discard reductions that, in conjunction with other measures proposed in the amendment, would eliminate the necessity for a complicated individual bluefin quota (IBQ) catch share system as proposed.
C. Individual bluefin quotas (IBQ) for longline vessels
CCA is very skeptical of the proposed IBQ catch share program. This appears to replace simple and predictable management measures such as the 6-month Gulf of Mexico PLL closure offered above with a complicated experimental system that may or may not suffice to provide additional dead discard reductions. We do note that the creation of this program would provide a windfall of profit of some $700,000 annually in perpetuity (under current U.S. Atlantic quota allocation from ICCAT) to purse seine vessels that have largely abandoned the bluefin fishery. We question why the agency feels compelled to move the wealth of this common property resource from the public good to the pockets of a select few individuals. CCA believes that this is bad public policy.
D. Shifts in allocation to the PLL sector
CCA does not believe that the proposed shifts in sub-quota from the angling sector and others to the PLL sector to cover dead discards is warranted. We understand that in the first round of annual allocations a transfer from the Purse Seine sector to other sectors, including angling, will remove or reduce the losses to the Angling and General Category, but with the possibility of latent purse seine effort reentering the fishery and innovative leasing arrangements that may arise in response to any IBQ program, the continued annual adjustments will by no means be guaranteed. Again the lack of any real economic analyses on the net benefits of these sets of actions is missing from the document.
In general, we find that the level of economic analyses provided in support of this amendment that primarily focuses on reallocation to be absolutely insufficient to provide policy makers with the proper information and context for making these allocation decisions. There are only rudimentary analyses of economic impacts based on recent catch and vessel performance and some simple generalizations of possible responses of the fisheries sectors to the proposed changes.
Allocation decisions should be based on the analysis of net present values and the economic benefits afforded to the nation as a whole, for it is the people of the U.S. who are the true owners of this and other common property resources. We find no detailed analyses of the affects of the proposals on every sector of the fishery (i.e. PLL, purse seine, angling, General Category sectors) as is required by law. It is past time that the NMFS began to pursue the use of modern bio-economic models and meta data analyses that truly present the impacts and benefits associated with such dramatic shifts in allocation among vastly differing sectors of the fishery.
CCA will use the coming weeks to develop our formal comments to the agency. We expect to pursue additional issues in those comments but offer up the ideas presented here as our response to what we believe to be the most critical issues contained in Amendment 7.