Comment from Laurie Mullett, Center for Biological Diversity

Document ID: NOAA-NMFS-2009-0029-0027
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: January 29 2009, at 01:00 PM Eastern Standard Time
Date Posted: August 20 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: December 15 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: January 28 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 8083ada2
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I am writing to urge the National Marine Fisheries Service to immediately enforce the Marine Mammal Protection Act Section 101 by banning swordfish imports until exporting countries demonstrate that their swordfish catch meets U.S. standards for protecting marine mammals. This 36-year-old law protects dozens of species of dolphins, porpoises, sea lions, whales, and other species I care about while safeguarding U.S. fishers from unfair competition with unregulated foreign fishing fleets. The time is long overdue to enforce the law and ban swordfish imports. Congress recognized that fishing posed a threat to marine mammal species when it passed this provision of the Marine Mammal Protection Act over 30 years ago. Enforcement of Marine Mammal Protection Act provisions for U.S. fisheries has led to the establishment of significant protective measures aimed at restricting harmful fishing practices and protecting marine mammal populations from unsustainable fisheries bycatch. Congress also recognized that, if the United States' efforts to protect marine mammals from fisheries bycatch were to be successful, it would have to exert pressure on fisheries of other nations to adopt similarly protective measures. The Marine Mammal Protection Act requires that all fisheries meet a "zero mortality rate goal" - in other words, that they reduce incidental death and serious injury of marine mammals to as close to zero as possible. This requirement has led to a number of important regulations on U.S. fishing, including gear-based requirements such as the use of pingers and net extenders, limits on the length of longlines, and as other measures like time-area closures, safe handling and release training and equipment, and mandatory observer coverage. All of these measures play a vital role in reducing fisheries' impact on populations of marine mammals and other species. Banning swordfish imports until source countries demonstrate that they meet these important standards would use U.S. market power to protect marine species I care about around the world and protect the economic interests of domestic fisheries. Therefore, I strongly urge the National Marine Fisheries Service to implement the ban immediately. Thank you for your attention to this important issue.

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