Comments on Bluefin Tuna EFP application
July 16, 2014
Highly Migratory Species Management Division (F/SF1)
1315 East-West Highway
Silver Spring, MD 20910
Dear Ms. Schulze-Haugen,
Coastal Conservation Association (CCA) appreciates the opportunity to present our concerns related to the exempted fishing permit application for purse seine vessels to harvest large medium Atlantic bluefin tuna (BFT) outside of the annual incidental purse seine retention limit. It must be emphasized at the outset that it is highly unusual for the name of the applicant, the amount of the quota involved, the names of the applicant’s boats, and the name of the scientist involved in this proposal to be redacted or omitted from the permit. Omissions of such basic, necessary information immediately raise a red flag as to the scientific integrity of this request and make it difficult to ascertain the true implications of this permit application.
The tragic recent history of BFT makes this a singularly ill-suited fishery for an exempted fishing permit of any kind. The bluefin fishery crashed more than 30 years ago due to overexploitation by both the United States’ purse seine industry and Japanese longlines. The purse seine fleet targeted smaller fish for canning, and tons of BFT were sold for pennies on the pound, shamefully under-utilized for things such as cat food. The fishery has never recovered from that period of intense pressure, even with no directed commercial fishing in U.S. waters.
Research has revealed that 2003 was a banner recruitment year for BFT and could form the basis of a sustained recovery. Most stakeholders agreed that this year class should be protected to the greatest extent reasonable. Nonetheless, it is exactly this year class that stands to be targeted by this exempted fishing permit application. We find it deplorable that an unnamed purse seine operator would seek to abuse the exempted fishing permit process to cash in on the merest hint of a recovery in this fishery.
It is very difficult to understand what, if any, science is to be achieved with this application. One of the stated “main” purposes of the permit is to determine whether a purse seine boat can catch its entire quota of commercial size BFT (greater than 73-inch) if the existing “unilateral arbitrary tolerance restriction of 15 percent by weight of total catch” is removed. In other words, the goal of the permit is to determine if a purse seine boat can catch its quota if the restrictions which are designed to discourage directed fishing for BFT are lifted.
References to providing tissue for sampling and specimens for aging appear secondary in nature to the “main” purpose of unrestricted fishing for BFT. Furthermore, the permit fails to provide reasoning for why an intense harvest method is necessary to provide such an influx of BFT samples. Is there a critical shortage of BFT samples that must be filled to further the scientific understanding of this species? Is NMFS requesting the supply of BFT samples to be increased by any means necessary? What exactly is the impetus for a permit to begin a directed fishery on a stock that is internationally recognized as being under almost insurmountable commercial fishing pressure across all the world’s oceans?
The exact amount of tuna to be harvested is withheld, but it is implied that the applicant intends to use a purse seine to “provide the fastest and cheapest manner to collect numerous samples” which, it can be assumed, the applicant then intends to sell for profit. It is our opinion that this permit is being sought purely for the financial gain of the applicant, with a thin veneer of science to enhance its legitimacy. It does not seem to fulfill any of the objectives for which the exempted fishing permit process is ostensibly designed to achieve.
This permit application appears to be no more than an attempt to develop a directed commercial fishery for large BFT, timed to take advantage of the smallest uptick in the fortunes of this battered stock. Any increased pressure on this species, particularly on the year class that is its best chance for recovery, is not warranted for any reason, and particularly not for those outlined in this rather feeble and opaque application. CCA encourages NMFS to deny this purse seine EFP application and send a strong message that abuse of the exempted fishing permit application process will not be tolerated.
Bill Bird, Chairman
CCA National Government Relations Committee