VSSA needs your help. NMFS just gave us new regulations for makos. Our government created an emergency rule but in this case made the new rule effective immediately then asked for comments by May 7. Kind of backwards to the normal process that gets public input BEFORE a rule is implemented. NMFS increased the size limit from 54 inches all the way to up 83 inches. That is a huge mako and a big jump in the regs.
We need as many anglers as possible to flood the NMFS site with comments opposing this new rule NLT May 7, 2018. You may use our suggested talking points below or use your own words / opinions but we need numbers to try to turn this around.
Here is the emergency rule:
Here is the portal for the draft rule:
Here are some the comments already made.
Suggest talking points (please copy/paste) to put in the comment section of the portal:
- Most of the impact is coming from commercial longline fishing. Most of the impact is from European Union countries. Given those two, it seems wrong that U.S. recreational anglers will disproportionately take the biggest hit. Instead of punishing everyone, conservation measures should focus on the biggest offenders.
- A jump from 54 inches all the way to 83 inches is simply too large for the recreational anglers to accept. A more reasonable increase should be considered like perhaps 58-60 inches.
- An 83 inch mako is a rare catch for the recreational angler. This action will result in most all mako fishing to end completely.
- An 83 inch mako contributes significantly to the breeding and rebuilding of the stocks. By targeting only the big breeders, this measure could have the opposite desired affect resulting in the decline of stocks.
- The recreational angler attempting to measure (even an estimate) of such a large mako shark put recreational angler crew at risk for unnecessary risk before trying to land such a large shark.
- NFMS is violating the Magnuson-Stevens Act by implementing a draft rule BEFORE public comment. NMFS should immediately withdraw the draft rule until the draft rule making process is followed by law.
- The data does not support the conclusions. Both cite insufficient data to make definitive analysis. East coast quotes several sources all disputing adult size, breeding size and population.
- Consider a temporary moratorium on mako tournaments as a conservation measure.
- Implement a more reasonable conservation measure for the recreational angler in the range of 58-60 inches.
Additional Analysis: As a result of the most recent stock assessment, NMFS, on December 13, 2017 determined the North Atlantic shortfin mako shark stock to be overfished, with overfishing occurring. This is a drastic and distressing change from the 2012 stock assessment, in which shortfin mako sharks were not overfished and are not subject to overfishing.
Considering that U.S. fishermen catch less than 5 percent of the overall harvest of shortfin mako in the North Atlantic, it appears NOAA Fisheries emergency action is not just to end overfishing of short fin mako sharks, but will, in many cases, eliminate any recreational fishing for shortfin mako sharks. The dramatic changes in regulations appear to hold U.S. recreational fisherman responsible for actions of the commercial long line fishery and European Union countries.
More distressing are the projections contained in the 2017 stock assessment indicating a total allowable catch of 0 MT would only produce a greater than 50 percent probability of rebuilding the stock by the year 2040. As additional information, research contained in the stock assessment indicates that post-release survival rates of Atlantic shortfin mako sharks are as high as 70%; however, the assessment could not determine if requiring live releases alone would reduce landings sufficiently to end overfishing and rebuild the stock. Moreover, shortfin mako sharks comprise less than 1 percent of total ex-vessel revenues in the pelagic longline fishery on average, and an even smaller fraction of total fisheries revenues in the potentially-affected fishing communities. This indicates, consideration should be given to possibly eliminating commercial fishing of any type for short fin mako sharks
These emergency measures are projected to reduce recreational landings of shortfin mako sharks by approximately 83 percent. Decreasing landings by this amount will all but eliminate recreational fishing for shortfin mako sharks. Additionally, increasing the minimum size from 54”fork length (fl) to 83”fl is more conservative than what was specifically recommended in Recommendation 17-08. However, since catch-and-release practices would still be permitted, a significant reduction in recreational fishing or charter/head boat activity is not expected. I disagree with this finding. The new size requirement is simply too large. Recreational fishermen rarely encounter 83”mako sharks. These Mako sharks are extremely aggressive and dangerous at boat side. Attempting to accurately measure a 250+ pound mako shark can be harmful to the shark and dangerous for the crew. Many will be killed or mortally wounded just so anglers can safely gain an accurate measurement. This further reduces the chances of the shark’s survival, which is counterproductive to rebuilding the stock. Additional consideration should be given to either keeping the 54” minimum fl or changing it to 72” fl for the U.S. recreational fisherman.
According to NMFS Northeast Fisheries Science Center tournament data, the larger minimum size limit may not significantly limit the ability of tournaments to land shortfin mako sharks, because most of the largest shortfin mako sharks landed at tournaments in recent years have been above the 83 inches FL minimum size limit. Shortfin mako shrks of this size are the breeders. Targeting these larger fish is just wrong and counterproductive to rebuilding the stock. Accordingly, if we are serious about rebuilding the stock, future mako shark tournaments should not be allowed.
Accordingly, VSSA urges NOAA fisheries to: reconsider the minimum size of shortfin mako for the recreational fishery and not allow short fin mako shark fishing tournaments.