Comment from Scott Hartley

Document ID: NOAA-NMFS-2011-0007-0006
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: February 09 2011, at 10:54 PM Eastern Standard Time
Date Posted: February 17 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: January 13 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: February 12 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80beb74d
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Dear Ms. Schulze-Haugen: As a member of The Billfish Foundation (TBF), I am aware that bluefin tuna, blue marlin and white marlin are severly overfished.  The proposed rule for which these comments are submitted is a step forward and we applaud Mustad for working with your scientists to develop a tool to reduce the bycatch mortality of bluefin tuna in the pelagic longline fishery and protect the large 2003 year class of bluefin while in the Gulf of Mexico.  I was further encouraged to learn that there was a slight reduction in the bycatch of blue marlin, but the large increase in the catch of white marlin bycatch is most alarming. I request that you go with Option 3, which, in addition to requiring use of the weak hook, would require time and area closures to protect bluefin and additional closures protecting marlin when they migrate through the Gulf.  I understand you are relying upon 2006 data to try to project displacement of longline boats that would need to move out of the closed zones, but this data is dated.  If closures are not preferred, I recommend that you implement (in addition to the weak hook) a bycatch cap limit, so long as observers are required on board each longline vessel during the bluefin and marlin migrations through the Gulf.  Once a cap is reached for any one species, the fishery should be closed for the season. Thank you for the opportunity to comment.      Sincerely, Scott Hartley

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