|(c) Doug Perrine/seapics.com|
In 2004, the U.S.
government closed the West Coast High Seas Swordfish Fishery when it
determined the by-catch of loggerhead sea turtles violated the
Endangered Species Act (ESA). Now, however, the National Marine
Fisheries Service (NMFS) may re-open this dangerous fishery just a few
years later, gearing up for a dramatic increase in swordfish fishing
with deadly consequences for imperiled sea turtles, whales, dolphins,
NMFS has announced it will prepare an Environmental Impact Statement
(EIS) to evaluate the impacts of allowing up to 20 boats to set up to
1.5 million hooks each year on 30 to 60-mile fishing lines. At a time
when NMFS should be looking for ways to further decrease the impacts of
longlining on ever-shrinking populations of marine wildlife, they are
posed to allow even more fishing and by-catch of sea turtles.
Help ensure NMFS honestly analyzes the impacts! Add your voice to the rousing chorus of opposition!
HOW TO SUBMIT COMMENTS:
1. Click here
2. Enter your first & last name under "Submitter Information"
3. Cut and Paste the sample comment letter under "Public Comment or Submission" or write your own
Public Comment ends September 8th!
(The proposal can be viewed on the government webpage by clicking on the pdf icon next to "View Document")
SAMPLE COMMENT LETTER
Dear Mr. Helvey,
I am deeply concerned that National Marine Fisheries Service is
considering approval of a West Coast-based High Seas Shallow-Set
Longline (SSLL) Swordfish Fishery. The PFMC made the right decision in
2004 when it implemented a ban on SSLL longline fishing west of 150° W
longitude in the Fisheries Management Plan. If approved, the High Seas
SSLL fishery would undermine successful conservation measures
protecting the critically endangered Pacific leatherback and threatened
loggerhead sea turtle as well as billfish, seabirds, marine mammals,
and sharks. I urge you to carefully consider the following points in
the Supplemental Environmental Impact Statement (SEIS):
• Evaluate a formal alternative the maintains the fishery closure
while also closing a loophole that allows WESPAC permit holders to
deliver landed swordfish along the West Coast
• Explain how no mortality of Pacific Leatherback and Loggerhead
species will occur in the High Seas Longline Swordfish Fishery.
Scientific evidence suggests that Pacific leatherback and loggerhead
sea turtle populations cannot withstand increased mortality, therefore,
any expansion of shallow-set pelagic longlining effort in the Pacific
would likely jeopardize the recovery of Pacific leatherback and
loggerhead sea turtles.
• Explain how authorizing up to 15 loggerhead takes-3x as many
permitted in the Incidental Take Statement for the West Coast Drift
Gillnet fishery-is consistent with the Endangered Species Act given the
loggerhead's declining population and the scientific uncertainties
regarding the implications of non-lethal fishery interactions.
• Explain how the High Seas Longline Swordfish Fishery will avoid
capturing marine mammal species whose incident rate of mortality or
serious injury is already above the required Zero Mortality Rate Goal
due to other fisheries
• Include the Western Pacific Fishery Management Council's (WESPAC)
recent recommendation to increase the "turtle cap" in the Hawaii
Shallow Set Longline fishery and lift set limit restrictions as part of
the environmental baseline and as part of the cumulative effects
analysis of the SEIS.
• Provide evidence for assumptions underpinning the purpose of the
High Seas Swordfish Longline Fishery. For example, the assumptions
that this fishery is likely to reduce drift gillnet fishing effort is
unrealistic since gillnet boats often are not equipped to venture far
enough offshore to fish in the EEZ and are not equipped with the
necessary longline gear.
• Likewise, please provide evidence to support the assumption that a
High Seas Swordfish Longline Fishery would (1) reduce imports and (2)
is necessary to decrease a reliance on imports given other regulatory
approached available through provisions of the Magnuson-Stevens Act and
import restrictions contained in the Marine Mammal Protection Act.
Thank you for the careful consideration of the above-mentioned issues. I look forward to your response.