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June 15, 2009

Dr. Jane Lubchenco
Administrator
National Oceanic and Atmospheric Administration
1401 Constitution Avenue, NW
Washington, DC 20230

Dear Dr. Lubchenco:

Highly migratory fish species, such as swordfish and bluefin tuna, that spend significant portions of their lifecycles in international waters present significant challenges to domestic and international management organizations. As you know, the National Marine Fisheries Service (NMFS) is responsible for managing Atlantic highly migratory species (HMS) fisheries in U.S. waters by establishing domestic regulations informed by the International Commission for the Conservation of Atlantic Tunas (ICCAT), of which the U.S. is a member. Indications are that, absent changes to current policies with regard to Atlantic HMS and our involvement in ICCAT, our fishermen face the imminent reallocation of substantial portions of long-held and hard-earned U.S. quota shares of north Atlantic swordfish and western Atlantic bluefin tuna to other ICCAT nations at the 2009 and 2010 ICCAT meetings, respectively. We ask for your assistance to ensure that our fishermen retain our allocated quota at upcoming ICCAT meetings and that the U.S. takes every opportunity to encourage HMS conservation among other ICCAT members.

In 2007, U.S. fishermen landed bluefin tuna and swordfish worth $3.5 and $8.6 million respectively, less than a quarter of the landed value of these species 20 years ago. We concede that harvest levels in the late 1980’s were unsustainable, but due in large part to the sacrifices of our U.S. pelagic longline fleet and our efforts at ICCAT, the north Atlantic swordfish stock is new fully rebuilt and being managed sustainably. Our bluefin tuna fisheries lead the world in cooperative research on the complex population dynamics of eastern and western stocks, and they currently operate under strict conservation safeguards that have supported stock rebuilding. Loss of ICCAT quota to other nations would have a detrimental impact on the hard-earned conservation gains of domestic HMS management by reassigning greater quota share to nations that lack the same conservation standards as the U.S., and it would further depress coastal fishing and seafood economies. This is a lose-lose proposition – lost U.S. jobs and lost marine resources.

We ask that you take three specific steps to help prevent the loss of U.S. ICCAT quota and ensure our industry and our conservation efforts remain strong. First, we ask that you act quickly to nominate a candidate to fill the Senate-confirmed position established in Title IV of the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act (MSRA). The NMFS and domestic HMS fishermen should be proud of the extraordinary steps they have taken to rebuild these resources and reduce bycatch in these lucrative fisheries. Our fleets, through cooperative research with your Agency, have developed bycatch reduction technologies and fishing strategies that have set the global standard for pelagic longline fishing. However, any reallocation of ICCAT quota represents a direct transfer of U.S. jobs and economic activity in our fishery-dependent communities to other fishing nations with weaker environmental standards. We look forward to your leadership in addressing our concerns and ensuring a bright future for our HMS fisheries.

Sincerely,

Rich Ruais
East Coast Tuna Association

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