A meeting for suggestions and comments to NMFS regarding the 2009 Bluefin tuna regulations will be held at;

march 17th, 2009 4pm to 6pm Location NOAA 1301 E West Highway Silver Springs MD. 20910

Directions http://maps.google.com/maps?q=Noaa%2...N&hl=en&tab=wl

OK southern Group I want more than 120 people at this one make a good show I hope to be there to meet you.

February 26, 2009

Dear Recreational and Commercial Bluefin Tuna Angler:

In consideration of our request to have you attend the National Marine Fisheries Service (NMFS) Hearing on March 4th (3:00 to 5:00 PM, Great Republic Drive, Gloucester, MA), I have written this note which should provide a basic understanding of the current situation, what is at stake, and a possible short term strategy to protect US interests. - NMFS HMS Advisory Panel Member, Steven James
The problem –
The United States is signatory to ICCAT (International Commission for the Conservation of Atlantic Tuna—a group of 20 nations plus the nations of the European Union (approx. 20 additional nations) and is bound by ICCAT mandates.
If US total BFT catch continues its current catch trend (below ICCAT allocated quota), the US stands to lose approximately 50% of its quota in 2011. This loss will be felt across the spectrum of US tuna fisherman including both commercial and recreational through our established percentage quota shares of the total US quota
ICCAT will reassign the unused portion of the US quota to another nation such as Mexico, Japan or Canada (it could even go to Belize) in 2011. In a nutshell, 50% of a natural resource that has traditionally been the livelihood of US Commercial Fishermen and one that is highly regarded by recreational anglers is in serious jeopardy of being permanently lost to another country or countries.
While US commercial and recreational fishermen fish under the most stringent and conservative self imposedregulations of any country in the world, ICCAT’s longstanding “use it or lose it” quota policy will serve to punish US fishermen for being conservative and going above and beyond the call of duty to rebuild Western Atlantic BFT stocks.
The US Commercial BFT retention limit is determined by NMFS and it is currently set at 73”. While the US uses 73” as its minimum commercial size, Canada, Japan and Mexico use the ICCAT minimum length of just 45”. Thus, US fishermen are required (by US/NMFS regulations) to release BFT that are perfectly legal to sell in other countries that fish the Western Atlantic. In essence, the United States’ unilateral higher level of standards and efforts (73” minimum for commercial fish) to preserve this magnificent fishery will result in not only United States loss of quota, but also will have a direct and immediate negative impact on the restoration of the bluefin population (decimation of juvenile fish).
If the US BFT quota is reassigned because we can’t fill the 2009 and 2010 quota, it will most surely be assigned to a country that uses 45” as its minimum commercial length. Further, any country that receives the US unfilled quota will be able to fish the 45” limit until the end of the stock rebuilding program which ends in 2018! This is likely to result in our US giant BFT quota being filled by another country with thousands of juvenile fish. If this whole thing seems unfair, it is because it is terribly unfair and a very inefficient if not impossible way to rebuild a fish population!
Clearly the US needs to convince ICCAT that it should not strip quota away from any country that chooses to fish under more conservative guidelines than those established by ICCAT. Unfortunately, this is a battle that will need to take place at the next 2011 ICCAT meeting as the rules are already established for 2009 and 2010. But a similar battle will be waged over loss of US swordfish quota this November 2009 because the US has not caught its swordfish quota in many years.
Because of ICCAT’s “use it or lose it” policy, the US long term biological goals of BFT stock rebuilding need to take a back seat to our short term political problems (quota usage) or the fish stocks that we have fought to preserve and rebuild are simply going to be reassigned to other nations. In essence, our past fishery management effort s will have been largely in vain unless we can land most of the US 2009 and 2010 quotas.
The United States’ ability to reach the 2009 quota is absolutely critical as the 2010 fishing year will not have concluded when the 2011 ICCAT meeting begins.
Unless something is done, transfer of US allocation to other nations will result in two very bad things—the permanent loss of United States allotted tuna catch (both commercial and recreational), and a significant reduction in tuna population via ICCAT approved commercial take of 45” by nations to whom that transfer is made.
The proposals -
Proposal 1 - Augment existing commercial retention limits with 65+ inch BFT as a temporary measure until either the availability of giant BFT become more plentiful or ICCAT recognizes the sacrifices of US fisherman (73” minimum) and subsequently changes the threatening measures to countries that fish with stricter standards than current ICCAT requirements.
The specific allocation caps for each category will be determined by the result of a mortality neutral formula. The intent is to maintain the current level of mortality by catching a predetermined amount of smaller fish at an overall predetermined lower quota level. Simply put, to catch more smaller fish to meet our quota we have to give up giant quota to keep the rebuilding plan on track.
This will entail determining how much uncaught BFT is at risk for transfer as a result of ICCAT policy, then complete the calculations needed to evaluate the neutral mortality option and then manage the specific allocation cap through a working group supported by NMFS. These results would then go to hearing for 2009 effort control.
Proposal 2 - Allow General Category BFT fisherman to determine landings based upon the number of days of any given trip. Currently there is a landing limit of three BFT per vessel per day with no consideration given for long range trips in the General Category. By allowing multi-day trips to retain more than 3 BFT, areas of offshore fishing that have been economically off limits due to operational overhead may become obtainable.
Proposal 3 - Increase the number of BFT retained by Recreational Anglers from one fish to two fish per day.

Proposal 4 - Allow Charter/Headboat Category fishermen to fish both recreationally and commercially in the same day and on the same trip.

Recreational Implications –
The US Recreational BFT quota has historically been determined by NMFS as a percentage of the overall US quota. Currently, the 2009 BFT Recreational Category quota is 19.7% of the US baseline quota. Because the Recreational quota is based upon the overall US quota, any US BFT quota that is re-assigned to another country by ICCAT will be felt in all Categories including the Recreational Category. Current Recreational size, quantity, and probable fishing season will be dramatically altered. Therefore, it is essential that General Category, Harpoon Category and the Recreational Category BFT fishermen work closely together to try to achieve the 2009 and 2010 US quotas.
Based upon historical landings data, the US has not reached its’ yearly ICCAT BFT quota since 2003. Further, the US has not been able to reach more than 50% of its’ ICCAT BFT quota since 2005. If the recent BFT yearly landings are an indicator of the 2009 landings, it would appear that we will be off by more than 50% of the US BFT quota unless something is done to remove or modify the overly strict effort controls imposed by the National Marine Fisheries Services.
Because the 65” BFT retention proposal is a category specific proposal (General Category and Harpoon Category), the existing US Recreational quota and size limits will not be affected by either proposal above. Therefore, Recreational anglers will still be allowed one “Trophy” BFT (73” or larger) per year if NMFS accepts the 65” proposal above. Anglers will also be able to pursue their regular full quotas of schoolies and small mediums.

Action Required –
It’s your fishery, be prepared to defend it. Attend the NMFS Hearing on March 17th (4:00 to 6:00 PM, NOAA 1301 E-West Highway Silver Springs MD)
You may submit letters and comments, identified by "0648-AX12", by any one of the following methods: Electronic Submissions: Submit all electronic public comments via the Federal eRulemaking Portal http://www.regulations.gov Fax: 978-281-9340, Attn: Sarah McLaughlin Mail: Sarah McLaughlin, Highly Migratory Species Management Division, Office of Sustainable Fisheries (F/SF1), NMFS, 55 Great Republic Dr., Gloucester, MA 01930