Please send your comments to NMFS on Proposed Longline EFP's

[Ron.38 Special]

Everyone please remember that you only have until November 20, 2007 to post your comments on NMFS proposed PLL research proposed for the FEC and Charleston Bump closed zones.

My comments have not been sent but they will include some basic facts:

1. NMFS says they have been monitoring PLL logbook and observer data on PLL's using Circle Hooks and gathering bycatch and mortality information and they now must do so in the closed zone. Where is that data? I know both myself and Mike Leech have tried to get the data and see what they really have , but to date I have found nothing and I believe Mike has had the same results. Does NMFS really have scientific opinions on the current bycatch reduction and mortality reduction of 18/0 offset Circle Hooks. The only scientific data I have seen on circle hooks is for non offset.
2. Assuming that the closed zone will stay closed, shouldn't NMFS make sure that we get exactly that data we need to make stock assesments, size assesments, and maybe get some mortality information. That would suggest a peer review of the scientific protocol and objectives of this "research". NMFS has the free input of may scientists and advisors at the level of the HMS advisory panel yet none of this information of details of the "research" sere shared with the panel.
3. Who is providing the scientific review and monitoring of the research and who will analyze the results?
4. What about "triggers"? When we have discussed this research fishing in the past, there was always the talk of "triggers" which would stop the fishing if results are not within the current objectives of if bycatch exceeds certain rates. NMFS estimates the bycatch. If we reach those levels at less than 300 sets, do we stop the fishing?
5. Modifications of closed zones. Presumably the purpose of the research in the minds of the PLL industry is to provide support for opening up or modifying existing closed zones. Under what conditions shoud that be considered. Is a certain bycatch accepatble because any modification of closed zones will reverse the gains made to date with the closure of these critical habitat areas.
6. One of the biggest concerns in the FEC is juvenile bycatch. How is NMFS going to collect data on this subject. Data to date on juvenile swords was done with non offset circle hooks, and showed a 50% mortality rate at less than 2 hours soak time. What is NMFS doing to look at that data. One , they are using offset hooks, and two, they need sat tag data to truly look at mortality rates.

Lots of questions, Not a lot of answers, and highly suspect with the lack of transparent regulatory action on this item.

NMFS needs to understand that we have a highly educated representation in the recreational swordfishery and we need to have transparent action by the HMS division so we can understand what is going on, who it is benefiting, and what the real plan is.

I suspect, after watching this issue for a few years now, that the move to open up the closed zone is ultimately to benefit just a few influencial fisherman and actually this proposal is being pushed by as few a one single PLL industry representative that has stated he will build new vessels to enter the PLL fleet if the FEC is opened again to longlines.

I'm not sure I'm willing to risk this fishery for one PLL vessel owner with the money to influence how things are done.

Please send your comments to NMFS before November 20 and let them know how you feel about this plan.

Fax to 301-713-1917 or email to PLL_ResearchEA@noaa.gov and use the identifier PLL Research EA in the subject.

Ron Coddington

[Broadbill-Pro]

Ron,

I agree with most of your comments, with exception to the motive for HMS to open the closed areas. BWFA made an attempt to open the areas on behalf of the PLL Owner (Vince Pyle) that you refer to. That proposal was rejected and as far as I know his vessel (Carol Ann) is not included as one of the 2 vessels in the proposed EA. Note that Carol Ann has provided HMS with a great deal of scientific data in the past at the Owners expense.

We both know the egg that NMFS HMS will have on their face if the quota is reduced and Hogarth has made it clear to Margo to take whatever steps are necessary to keep this off his resume.

Pointing a finger at them in regard to bending over for the PLL industry at this point is unfair and untrue. I don't see why you must finish an imformative post with this trash? You understand the importance of the EA, so why create turmoil?

[The BEAST]

Originally Posted by Broadbill-Pro

We both know the egg that NMFS HMS will have on their face if the quota is reduced and Hogarth has made it clear to Margo to take whatever steps are necessary to keep this off his resume.

Vinnie,

Maybe they should scrape the egg off their face into a hot frying pan and make a side of grits to go with it.

I have only one question for your post. This sounds like a personal/political agenda. Are we supposed to risk an entire species that swims the Florida coastline for one man's resume?

[Broadbill-Pro]

When that resume could include the single worst conservation decision that this hemisphere will ever experience, I would say yes and he should hang his head in shame if it happens of his watch.

You have no clue of what the modern day unrestricted PLL is capable of. Turn our unused quota over to foreign vessels and in short time you will find out that nothing gets thru the Yucatan Channel.

[The BEAST]

I do have an idea what the PLL can do... that is the problem. I am already afraid to see what happens when they and the buoy guys figure out a proficient way to fish the bottom during the daytime.

2 questions???

1. What keeps all these "FUD" PLL of yours from fishing their entire quota now from the Yucatan channel inste of waiting until they see what we do with our quota?

2. Please explain the difference in 2.2 million pounds taken off the Florida coast and 2.2 million pounds taken off the Yucatan channel?

What it sounds like to me is it is still 2.2 million pounds of dead Swordfish is still 2.2 million pounds of dead Swordfish.

My analaogy still remains... I would rather take the chance that some of the chickens which leave the coop just might survive the fox than to stick the fox inside the coop and let him eat all he can.

Allowing the PLL in the FEC to catch 2.2 million pounds is exactly like putting that fox in your hen house.

WAIT!!!! Question #3. Why doesn't the US PLL go down to the Yucatan or any other international waters to catch their quota, just as these other countries do from half way around the world?

[The BEAST]

When that resume could include the single worst conservation decision that this hemisphere will ever experience, I would say yes and he should hang his head in shame if it happens of his watch.

By the way Vinnie, you participated in THE single WORST Swordfish conservation disaster in the past half century.

That's what I am afraid of. All the maybe's could's and might's!

[Ron.38 Special]

Here's my comment,
November 20, 2007

Margo Schulze-Haugen
United States Department of Commerce
National Oceanic and Atmospheric Administration
National Marine Fisheries
Office of sustainable Fisheries
Highly Migratory Species Management Division
1315 East-West Highway
Silver Springs, Maryland 20910

RE: Draft Environmental Assessment To Conduct Scientific Research Experiments Using Pelagic Longline Gear in Portions of the East Florida Coast (EFC) and Charleston Bump Closed Areas of the Atlantic Ocean, October 2007

Gentlemen:

In this very short comment period, I have reviewed the reference document and the proposed EFP’s and have the following comments.

1. In consideration of the significant comments from both the public and from Florida politicians and State Government Agencies, I strongly suggest that HMS has neglected to properly serve the public in having such a short comment period. The short comment period gives the impression to the fishing public that NMFS and HMS is trying to “slip” something by us and avoid the negative comments that are obvious with this kind of proposal. Past history shows that this type of fishing will result in significant public comment and proper time should be given for such input from the fishing public. Comments from the State of Florida governors office certainly are still applicable to this proposal which differs only slightly from that originally proposed by Bluewater Fishermens Association.
2. The draft Environmental Assessment fails to address the significant public comment received during the last EFP request for public comments. The simple obvious difference is the fact that it is now proposed by NMFS who has simple put their letterhead on the Bluewater Proposal.
3. Technical review of the draft EA shows that the government staff has failed to address the issues with the best available science. Certainly any review of anticipated total catch of target species and anticipated bycatch, should incorporate significant data collected on circle hook gear since its requirement in the PLL fishery in 2004. The calculation of estimated catch and bycatch does not use newer information regarding NMFS acknowledged changes in catch including both increases and decreases in catch rates due to Circle Hooks. Failure to include the analysis of this data is misguided at best, and violates the intent of the EA.
4. The draft EA, suggests a limited program with little or no environmental or sociological impacts. This statement and finding contained in the EA neglects to consider the fact that fishing effort planned in this EFP exceeds the 50% level of historical effort in the study area and in fact is more than 2.5 times the historical effort in the month of January. This impact is not as small as suggested and may have significant affects on the quality of the recreational fishing experience in the study area. Gear conflicts have been underestimated and the sociological impacts to the recreational fishery ignore the affect of public perception of the changes in the recreational fishery due to PLL effort in the area. Quite simply, many planned recreational trips and CHB trips will be canceled due to this public perception and the facts of the incompatibility of PLL’s and recreational gear.
5. The draft EA fails to accurately predict the interaction with non target and protected species due to the failure to utilize best available science in the preparation of the draft EA.
6. The draft EA fails to take into account the relative abundance changes in the target and non target species in the closed zone that has been without PLL effort for over 6 years. This failure to include these facts in the EA make it unable to accurately predict the affect of the research fishery planned with this ill advised “experiment”.
7. Research protocol is apparently unavailable at this time for review however, it is impossible to understand or predict how NMFS scientists are going to use the circle hook only data to accurately measure the decrease or increase in catches of target and no-target species encountered during the “research fishing expedition”. There is no way to compare the previous POP or PLL logbook data with the anticipated changes in relative abundance of all species in the area that has been closed to PLL for so long. Research protocol to accomplish this study without the use of “J” hooks is impossible to review at this time, but is highly suspect at best and will not stand up to peer review.
8. NMFS has ignored previous comments for the multiple requests to fish the closed zone. The most common comment made on previous EFP’s is the suggestion that research be carried out in existing open areas fist then move to closed areas if the data warrant the continued research fishing. Where is existing POP or logbook data on the changes in catch rates of target and non-target species from circle hook effort within the PLL fleet.
9. Most important is the fact that NMFS has sidestepped the issue of turtle interaction and apparently has grossly miscalculated the impact to leatherback turtles.
10. This reviewer suggest that catches of target and non-target species will be greater than that predicted by a factor of at least 300% based on communications with existing PLL captains familiar with the study area. Why such a difference in expectations between the preparers of the EZ, and the users who spend most of their time on the water?
11. Transparency in the process, the review of data, and the research protocol is necessary, especially on this very controversial proposal. If fishing is conducted in the area, after the correction of the gross errors in the EZ, timely sharing of the total catch, bycatch, and protected species interaction is imperative to gain and maintain public support for the fishery management process.

It is important to note that current high numbers of bycatch reduction are due solely to the fact that we have closed areas. Virtually all of the bycatch reduction in the PLL for all species is due to this fact that effort is restricted or prohibited in high bycatch fishing areas. Prior to any attempt at modification of any closed areas, or prior to the use of closed areas for bycatch research, proper research must be conducted in open areas and the data be submitted for peer review and analysis.

NMFS and the HMS division must recognize that significant input against this proposal have already been given by the State of Florida, our politicians, and our Environmental and fisheries management agencies. By resubmitting this proposal under the NMFS letterhead and allowing only a short comment period, it is obvious that comments will be less in number than the last comment period on this subject.

After correction of the gross errors in the EA, and prior to the approval of any research fishing, the revised EA must be submitted for public comment. At that time, the information on the research protocol should also be submitted.

It is unfortunate that this project and its plans was not brought before the AP members for review and comment prior to the public comment period. The great expertise from the scientific community, environmental community, commercial fishing community and the recreational interests, which are gathered in the room at AP meetings, could have provided input and suggestions which could have avoided the delays which will be experienced if NMFS rewrites the EA as should be required under federal guidelines due to the errors and omission in the draft EA.

NOAA, NMFS, Office of Sustainable Fisheries, and Highly Migratory Species Management Division must understand that this proposed is among the most controversial of any proposed by NMFS and all questions or concerns with this proposal must be addressed without rushing into action with such a poorly prepared plan. Any fishing in the closed zones must be done with the assumption that entry into those zones with PLL gear will be limited and may not be repeated for another 6 years or more. Therefore all steps must be taken to get the maximum information from the limited fishing in the zone. We are not ready to do this research in the closed zones without first doing acceptable research in the existing open zones with good results.

Sincerely,


Ronald J. Coddington, P.E.
HMS Advisory Panel Member

[Broadbill-Pro]

Just think you could of had a Miller Lite instead

[rollin]

i cant even believe that you guys are talking about this again.

its rediculous.

every fisherman, recreational and commercial, in this area knows that LLs cannot operate here in the straits without significant damage to breeding stocks of swords, marlin, sails, tuna, shark, etc., etc.

please tell me why the other thousands of sq. miles of ocean left open to commercial LL operators isnt enough.

please.

R

[Ocean Outlaw 420]

Originally Posted by rollin

every fisherman, recreational and commercial, in this area knows that LLs cannot operate here in the straits without significant damage to breeding stocks of swords, marlin, sails, tuna, shark, etc., etc.


R

Maybe it should be closed to recreational also since it is a breeding ground.

[rollin]

Originally Posted by Ocean Outlaw 420

Maybe it should be closed to recreational also since it is a breeding ground.

fine. close it. i'm sick of this lame arguement from the comm. sector. its well known that rec. pressure alone causes absolutley no negative affect on the rebuilding of the sword stock, or any other stock for that matter.

if it takes the loss of the rec. sword activity in the eez to keep out the LLs then they SHOULD close it to save the recovering stocks of all the other species that were decimated as "by catch" when they were allowed to operate here.

i was out yesterday and heard someone report an 85lb yellowfin caught in 900 feet of water off of pt. everglades. last year there were a dozen (just that I know of) big YFT caught right here in spring.

let the LLs back in here and kiss the YF recovery goodbye, along with recovering marlin, sail, wahoo, etc., etc.

R

[Broadbill-Pro]

Rollin,

You just can not clutch the concept that US natural resources are not reserved for the privileged only.

There are a dozen species that without regulation would be extinct at the hands of the recreational sector. BTW, Yfin tuna are doing quit well worldwide.

[The BEAST]

Originally Posted by Broadbill-Pro

You just can not clutch the concept that US natural resources are not reserved for the privileged only.

There are a dozen species that without regulation would be extinct at the hands of the recreational sector. BTW, Yfin tuna are doing quit well worldwide.

Vinnie,

You're right! As well, majority of the species do not belong to the minority of the fisherman. Here comes the feed the masses line! And what type of people are these PLL fishermen anyway.

I received another PM Saturday from an individual who recieved their SFC name Saturday, obviously only using it to PM me. Of course, 0 posts! This PM contained NO (0) threats. In this persons case... he brought up a post I made 6 weeks ago and openly admitted that it was all about the money. Of course he threw in a couple of back-handed shots but no big deal there.

As I've stated before, from a PLL perspective, it isn't about the Swordfish quota because they frankly can't afford to fish for them at market prices and more fish on the market would only make the prices drop. As I said many times before, it is about PLL access to the FEC for more profitable species.

I believe 100% in open discussion. If you have something to say... Butch up and POST IT openly. Don't use bogus names and behind the scenes PM's. Although doing things the sneaky way and slip it by the public does seem to be the MO of the PLL and NMFS. These tactics just solidify, not soften, my opinions and surely doesn't help their cause. I will not entertain a private discussion on these pertinent matters.

How many PLL permits are out there? That's 3 PM's now. I guess I can expect a few more discreet messages from these PLL pillars of the fishing community.

PS. Go ahead, Vinnie... Name that dozen species that you "believe" would be extinct at the hands of the recreational fisherman. I want to hear this. If the commercial sector was left unchecked most of us can name a dozen species that would be factually extinct and many that are still in critically low numbers. In the last 100 years and as recent as 10 years ago, it is a known fact that commercial hunters, which themselves are extinct now, and commercial fisherman have/will decimate a species for the money. Unchecked, it would continue on to this day.

I doubt any of us are going to run our boats to the Pacific to fish for YFT so "worldwide" speculation as to the health of the YFT stock is irrelevant. The Pacific Ocean is twice the size and twice the volume of water than that of the Atlantic yet only yields 60% of the worlds fish. Let's confine our facts to the North Atlantic where all the questionable species are accessible in OUR waters. Stop tossing around such insignificant rhetoric which has nothing to do with our problem at hand.

[rollin]

Originally Posted by Broadbill-Pro

Rollin,

You just can not clutch the concept that US natural resources are not reserved for the privileged only.

There are a dozen species that without regulation would be extinct at the hands of the recreational sector. BTW, Yfin tuna are doing quit well worldwide.

i dont buy it BBP.

no else should either. recreational fishing, properly regulated (as we already are) cannot cause any declines of any species. you can already catch your one fish grouper limit in the gulf while watching a comm. boat on the same spot catch as many as they want. is that fair? i dunno.

i respect comm. fishermens rights to make a living and dont mind 'em having different limits within reason, but in some cases its gettin' regoddamndiculous already.

you gotta look at this particular problem as our problem - ours - here. forget whats happening in the gulf, the pacific, the rest of the damn planet for awhile and lets try to solve the one we have here.

in the 60s and 70s, before the LLs fished 'em into (local) extinction, you could catch giant bluefin between here and bimini. lots of big YF too. then the LLs fished em out. since the ban, the YF are actually starting to show up here again - i GUARANTEE that if the LLs are allowed back in that'll be the end of that happy trend. that fact had NOTHING to do with rec. pressure - do you agree?

the problem here is geographic. the straits act like a bottleneck for palegics migrating up and down the SE coast. THATS why the PLL guys want back in here so bad - less distance to travel lookin for productive water. unfortunately, when the fish are gettin all bottled up between the coast of SEF and the bahamas bank, and we nail 'em constantly as they go through, its too much pressure for the stocks to proliferate and they become decimated. THIS IS WHY PLL GEAR CANNOT BE ALLOWED IN THE STRAITS!

this aint rocket science - its common sense - which apparently the comm. sector has none of.

and by the way, a simple solution to the qouta problem - lower it for everyone - worldwide. the stocks would benefit, the comm. sector would benefit, (less product (fish) and same or even larger demand (people eatin' fish) equals higher market prices - basic economy 101).

i was hoping that i could catch a YFT once in my life without having to fly to louisiana.

R

[Broadbill-Pro]

Rollin,

My comment was directed towards unregulated recreational fishing, I would hate to see the state of snook stocks without a size and time regulation on recreational fisherman.

PLL have been limited to 1 Bfin south and 2 Bfin north of Hatteras as far back as I can remember, atleast the early 80's. The current regulations that allow 1 , 2 or 3 fish depending on a percentage of the total catch does not allow much more. If your speaking about Japanese PLL targeting Bfin then I will agree with you. Reduction in Bfin stocks can not be attributed to US PLL'ers. You should look at the general catagory/recreational fisherman in the Northeast for answers to that problem.

FYI, It was not until the early 80's that American Fisherman took advantage of the high prices for Bfin in Japan. We learned to care for the product and developed a system to ship the fish over-seas in a timely manner. Prior to that many Bfin were regarded as "no value" and dumped. Same goes for Yfin, prior to the recent sashimi craze many Yfin were not worth the ice to chill them. Times have changed in regard to tuna, market price is more reliable, overhead costs are less than swordfishing and there is a constant demand for product. It was not always that way.

I have said in the past that if our usused quota was deducted from the North Atlantic total quota, the pain would not be nearly what it will be when it is given to Nations fishing on the spawning grounds that our fish depend on.