Following are some technical points (or use the whole letter) for you to use in a letter to Fish and Wildlife about the proposed CITES listing of BFT. Letters must be submitted by Sept. 11, 2009. If you are a fisherman and have seen abundances of fish, tell them that also. Speak from the heart, the fishery means so much to many of us they can not ignore that. ABTA wants ICCAT fixed and CITIES is not an ICCAT replacement tool. ICCAT manages 14 HMS species and has met objectives for only 4 of them. Fix ICCAT now or look forward to cascading CITES listing for those other HMS that are also in trouble.
BAMPY
Mr. Robert R. Gabrel, Chief
Division of Scientific Authority
U.S. Fish and Wildlife Service
4401 North Fairfax Drive
Room 110
Arlington, VA 22203
By fax to 703-358-2276 or by e-mail to
scientificauthority@fws.gov
Re: Cop15 & Northern Atlantic Bluefin Tuna
Dear Mr. Gabrel:
I am opposed to the proposed CITES listing for Atlantic bluefin tuna.
American fishermen are not the cause of current CITES momentum and have always followed Bluefin scientific advice and abided by international quotas. A CITES listing is not the remedy for the Eastern/Mediterranean failure to conserve. Nor does it take the place of proper fishery management or creating the political will to empower ICCAT to do the right job. . Following are my rational for opposition:
1) The latest 2008 ICCAT SCRS stock assessment provides no evidence or suggestion of a threat of the northern Atlantic bluefin tuna (BFT) going biologically extinct.
2) I have not seen any suggestion by any mainstream, credible bluefin tuna scientists to the effect that there is any significant level of capability of a fishery or mankind to fish to extinction a species with the reproductive strategy of a highly migratory, highly fecund, widely distributed tuna species such as the Atlantic bluefin tuna.
3) Catch rates would be uneconomic for fishermen to undertake the pursuit of the last several hundred or several thousand pairs of mature BFT.
4) Table 4 of the latest stock assessment suggests the capacity of the eastern Atlantic spawning stock to compensate. In the last 10 years the average spawning stock biomass has dropped almost in half but the average recruitment has increased by a quarter of million fish. A stock recruitment relationship cannot be the justification for an argument of extinction or CITES listing.
5) The 2008 ICCAT eastern stock assessment by ICCAT does suggest a risk of fishery collapse for the eastern Atlantic and Mediterranean stock not to be confused with species extinction should the Mediterranean fisheries catch and effort for BFT remain out of control. Through the years there are many examples of fishery collapses which have not led to biological extinction of any tuna stock.
6) Many scientists now seem to prefer describing BFT as “metapopulations” or “contingent hypothesis” group theories with one of the implications being survival of the species even if one or more of the sub-populations is under extreme stress and fishing pressure.
There seems to be some consensus that, at least three distinct populations of BFT exist: an eastern Mediterranean population which while potentially mixing with western Mediterranean BFT rarely leave the Mediterranean Sea; the largest spawning stock of BFT the western Mediterranean stock which migrates and feeds throughout the Mediterranean Sea and the western Atlantic Ocean (with the exception of the Gulf of Mexico) and the western Atlantic BFT which spawns in the Gulf and migrates and feeds on both sides of the Atlantic and may enter the Mediterranean (4.5% of a sample of farmed fish through micro constituent analysis) but does not likely spawn when present there. More recent electronic tags seem to be leading at least two prolific BFT tagging scientists to suspect a third spawning assemblage in the Atlantic possibly locating in the central Atlantic, northeast of Bermuda or east of Bahamas or the Caribbean Sea. Prior evidence of bluefin larvae in the Gulf of Guinea and off North Carolina has been published.
I believe that the view described above is the proper context to view the potential eastern “fishery collapse” of a contingent or assemblage i.e. there is no threat of extinction to the stock but may well be danger to an assemblage, maybe a very large assemblage of BFT being fished down or out.
7) Even though the BFT fisheries collapsed in the Norwegian Sea, North Sea and Brazil, landings have since been reported. The collapse of the Nordic fisheries some 51 years ago still yielded catches over 100 tons in the 1990’s. And, The Brazilian fishery reported 13 tons in 1999 after the collapse in the 1960’s. Clearly an uneconomic fishery situation, but no doubt some evidence that collapsed fisheries cannot be interpreted as being based on extinction of the populations once supporting strong fisheries reported to ICCAT.
In 1989 the Southern Bluefin tuna stock collapse was accepted by the participating fishing nations when the total catch dropped to the 10,000 to 15,000 mt level. 20 years later the Total Allowable Catch for the “collapsed” fishery is now set by the CCCSBT at 11,810 mt. Another example to demonstrate that with a highly migratory, highly fecund tuna species -- collapse of the fishery is not an indication of threat of extinction or imminent extinction of the species.
9) Japan has objected 7 times to any CITES listing of any marine species. It is likely that Japanese markets will remain open to BFT if CITES 1 is obtained. Libya, Turkey, Algeria, Taiwan, Philippines, etc. would seek windfall profits to supply shortages from countries likely to abide by the CITES decision. Mean while American fishermen will pay the price for abiding by the law and conserving.
10) The latest western stock assessment (that which American fishermen draw quota from) demonstrates that with the 2010 reduction in western quota to 1,800 mt (actual catches are already considerably less) we technically will no longer be overfishing the resource. Under ICCAT’s SCRS guidance, a conservative scenario of 1,800 mt catch the western stock will be rebuilt to the biomass that produces maximum sustainable yield under the low recruitment scenario by 2015, essentially in 5 years or less given current catches below the suggested TAC.
11) An Appendix I listing for bluefin would punish, inflict severe economic injury, devastate fishing families of the countries most responsible for improving scientific understanding of the resource and following the scientific advice.
12) All of the measures (alternative to CITES) are in place for trade restrictions in Japan and the U.S. to accomplish the objective of restricting catches by denying markets and profitable farming and fishing to force the violating countries into compliance.
13) Some have suggested that a CITES listing could be employed only to bring under control the eastern fisheries and that the western fisheries could continue their domestic fisheries under authorized ICCAT quotas and essentially retain status quo. First, Canada has no significant domestic market for its bluefin tuna. Although we are a net importer of BFT the U.S. market would not absorb our legitimate, sustainable production of BFT in the timeframe that they are traditionally available to our fishery i.e. June through October. The eastern U.S. seaboard lacks the minus 60 degree freezer capacity to store surplus seasonal production for the sashimi market and even if the capacity developed the product would likely lose significant value.
14) The U.S. industry has already urged the U.S. government to demand reopening of the issue at the 2009 meeting in Recife, Brazil to change the recommendation and follow the scientific advice on catch limits and closed seasons.
15) Additionally, I support the American Bluefin Tuna Association’s (ABTA) extensive comment letter of September 11th.
We request your support of NOAA and the State Department to utilize any and all leverage with the EC to follow the ICCAT SCRS advice and ICCAT Convention Treaty to adopt conservation policies that will allow sustainable maximum yields of eastern Atlantic and Mediterranean bluefin tuna. Please oppose a CITES listing for BFT.
Bluefin CITES form letter 
