As noted in earlier TBF articles and comments, the North Atlantic swordfish recovery presents a unique challenge – responsibly managing increased landing limits at levels that will insure continued recovery of swordfish stocks.  This proposed rule does not consider any modification to the closed zones, changes to the new buoy gear fishery, or recommendations for a rod and reel handgear commercial fishery.

Catching more of the U.S. baseline quota of 3,907 metric tons, would contribute to retaining an effective negotiating voice before the International Commission for the Conservation of Atlantic Tunas (ICCAT), where most negotiating voices are governmental and commercial fishing interests.  If the U.S. commercial negotiating voice were to be diminished because the U.S. fishery could no longer compete with other nations, then restraints and conservation measures would most likely diminish as well at the international level, impacting all U.S. highly migratory fishing interests.  TBF is networking with recreational fishing interests in other nations to increase the recreational fishing voice on all delegations.  A better balance in negotiating voices can improve conservation, management and sustained production of healthy stocks of swordfish.  However, while striving catch more of the U.S. quota, it may be wise to exercise some restraint to avoid initiating a stock decline once more.    

The recovery (abundance up to Maximum Sustainable Yield, or MSY) of North Atlantic swordfish continues to generate excitement.  Recovery benefits that are "up for grabs" in this rule are the result of ten years of management restraints coupled with Mother Nature's production of several large year-classes of juvenile swordfish and longline closures to protect juvenile fish.  This is a success that will hopefully be repeated by white marlin and blue marlin.

The real challenge this Rule creates is how to continue exercising some conservation restraints while authorizing increased landings.  The National Marine Fisheries Service (NMFS) cannot abandon their responsibility to protect juvenile swordfish, their nursery areas and critical spawning zones or other seriously overfished species, such as Atlantic marlin and bluefin tuna.  At the same time, all fishing interests desire to "be rewarded" for the restraints that contributed to the stock's recovery, and the U.S. should be a competitive nation before ICCAT.

The Preferred Alternatives: 

Issue 1 - Retention Limits

Alternative 1c:  Increase retention limits for commercial vessels with an Incidental Swordfish Permit (48 vessels eligible out of 91) from 2 to 30 swordfish per trip (trips average 8 days), except for vessels participating in the Squid Trawl Fishery, which would go from 5 to 15 swordfish per trip. 

TBF can support this alternative to help catch the U.S. quota, but there appears to be no government analysis of the potential increase in incidental marlin catches that might be caught as the vessels strives to land the new authorized incidental take of 30 swordfish.   If the proposed 30 fish retention number is the average number of swordfish currently being discarded dead through highgrading for the two largest they can now sell, then there would be no additional negative impacts.  However, monitoring of marlin bycatch to determine if it increases is essential.  If marlin bycatch increases, the newly authorized number of swordfish that can be retained needs to be reduced. 

Most of the Incidental Swordfish Permitted longline vessels target yellowfin tuna in the Gulf of Mexico, the fishery that produces the highest incidental catch of Atlantic marlin.  Both species of Atlantic marlin are seriously overfished and cannot withstand additional pressure and mortality.  The same fishery also has an incidental catch of bluefin tuna in the Gulf, an internationally recognized spawning ground on which targeted longline catch is not authorized.  The U.S. commercial bluefin tunas fishery is in severe decline; therefore, bycatch levels of bluefin must be monitored. 

More consideration should also be given to reinvigorating marlin stocks by proposing measures to reduce incidental catch of marlin and bluefin tuna in the Gulf.  This could be accomplished either through more zones closed to longline gear or a possible transition to green stick gear, if research indicates the incidental catch would be lower with green sticks.  

Alternative 1f: Increase the bag limit for recreational HMS Angling Permitted vessels (25,238 vessels) from 3 to 4 swordfish per trip, but retain the 1 swordfish per person bag limit.

TBF supports this Alternative as a means to help catch the U.S. quota; however, most of the recreationally caught swordfish are caught in the zone closed to provide protection to juvenile swordfish.  Most of the fish currently caught in the zone are juveniles.  TBF recommends that an increase in the minimum size limit be implemented for all swordfish caught from within closed zones. 

Retaining some protections for juvenile swordfish is important.  Half the swordfish population does not become sexually mature until five years of age, at which the average size is 164 pounds, whole weight.  Full sexual maturity is not achieved until age 8 at which the average weight is 230 pounds, whole weight.   

Illegal sales continue to be a point of concern, a point that demands closer enforcement oversight.  The newly authorized buoy gear, a commercial hand gear, is already generating conflicts with the recreational fishery.  Consideration should be given to a rod and reel handgear commercial fishery, with more than the current number of permits being issued.

Alternative 1e: Increase the retention for the recreational HMS Charter/Headboat permitted vessels (4,173 vessels) from one swordfish per paying passenger, up to a maximum of 6 swordfish per Charter Vessel and 15 swordfish per Headboat, per trip. 

TBF can support this Alternative as a means to help catch the U.S. quota.  

Issue 2 – Vessel Upgrading Restrictions

Alternative 2e: Modify vessel upgrading restrictions for vessels that are authorized to fish for swordfish and tunas with pelagic longline gear (i.e., vessels permitted as Limited Access Swordfish [Directed and Incidental – 277 total vessels]; and Limited Access Shark and Atlantic Tunas Longline permits –176 vessels of the 277).  These vessels could be upgraded, or permits transferred, as long as the upgrade or permit transfer does not result in an increase in vessel size (LOA-length overall, GRT- gross tonnage, and NT – net tonnage) of more than 35 percent of the vessel first issued HMS limited access permit.  The Alternative also removes horsepower upgrading restrictions.  Some vessels have already taken advantage of an earlier approved upgrade allowance of 10%, leaving those only a 25% upgrade option if this Alternative is approved.

TBF supports an increase in size and horsepower for the longline vessels for it provides greater safety and range for each trip, which should provide a better opportunity to fish for the quota.  Larger vessels fishing further from closed zones within U.S. waters should also reduce user group conflicts.  However, if the increases in length and horsepower also results in larger drums and longer longlines on each vessel, restrictions should be approved to restrict the longline length to no more than the current average length to avoid longer soak times and increased incidental catch mortality.  The larger and more powerful vessels should be prohibited from fishing buoy gear in the closed zones.

