Magnuson-Stevens Fishery Conservation and Management Act; General Provisions for Domestic Fisheries; Application for Exempted Fishing Permit

1985 individuals sent the same comment via email as members of Turtle Island Restoration Network Mr. Fanning, I urge you to deny the exempted fishing permit (EFP) covering the activities proposed in both Mr. Brown and Mr. Bateman's EFP application identified as "midwater snap gear." Longline-based gear types are detrimental in terms of bycatch, historically eradicating many vulnerable marine species, including sharks, birds, whales, dolphins, and endangered sea turtles. Resources should be allocated to further research and development of more sustainable, scientifically based fishing gear types like deep-set buoy gear (DSBG) and linked-buoy gear (LBG), and not to destructive pelagic longline-based gear type. Midwater snap gear closely resembles destructive pelagic longline-like gear that has shown time and time again to produce unacceptable levels of bycatch. Recent 2019 NMFS issued shallow-set longline (SSLL) EFP caught 7 blue sharks for every 1 target swordfish1, and in the past five years, Hawaii permitted SSLL fishery has caught 5 blue sharks for every 6 swordfish2. There is minimal scientific evidence suggesting that reducing the line size to 5 meters will make this fishery a sustainable option and we can expect it to continue threatening marine wildlife. The revival of longline fishing off of the West Coast could result in the extinction of the critically endangered Pacific leatherback sea turtle. Populations of Pacific leatherback sea turtles have declined by more than 80% over the past 40 years, primarily due to hooking, entanglement, and drowning in fishery gear such as longlines. The National Marine Fisheries Service (NMFS) now lists Pacific leatherbacks as one of nine marine species most likely to go extinct3. Approximately two-thirds of leatherbacks captured off the California coast are subadult or adult females4 and are critical for population recovery. The loss of one turtle is one too many and thus, cannot allow longline fishing gear off the west coast to return to give the Pacific Leatherback a chance at recovery. We are in the midst of a a biodiversity crisis, with around 30% of marine mammals, sharks, and reef-forming corals threatened by extinction. To combat this catastrophe and meet both President Biden and Governor Newsom's goals of conserving 30% of the ocean's by 2030, we need to stop investing in unsustainable fishing gear of the past. With other potential low bycatch fishing gear such as DSBG and LBG in development, there is no rationale to continue to test flawed pelagic longline-like gear that has propelled vulnerable species toward extinction. Thank you for considering my request to deny an EFP for midwater snap gear. Sincerely, 1 (Preliminary Report on the 2019 Swordfish Longline EFP Fishery, Captains David Haworth and John Gibbs, available at https://www.pcouncil.org/documents/2020/05/informational-report-11-preliminary-report-on-the-2019- swordfish-longline-efp-fishery-captains-d #) 2 Hawaii and California Longline Fishery Logbook Summary Reports, available at https://www.fisheries.noaa.gov/ 3 resource/data/hawaii-and-california-longline-fishery-logbook-summary-reports 3 NOAA Fisheries, Species in the Spotlight: Priority Actions: 2016-2020, Pacific Leatherback Turtle Dermochelys coriacea (2015). 4 Benson et al. (2007), surpra n5.

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