Comment from Anna Atkinson

Fishing for hammerhead sharks should be restricted because the worldwide population went down 15 to 20 percent, according to the 2009 study referenced in the rule. Reduction in the fishing of the species is necessary to maintain the current population levels, according to the study. The rule states that only two percent of PLL trips caught hammerhead sharks in four years, and that the rule may have minor but not major benefits to the species. The rule doesn’t target forms of fishing that target shark species outside ICCAT fisheries. Although bottom longline, gillnet, or handgear catch the sharks in need of protection, the NMSF is not banning the capture of the endangered sharks by way of this kind of gear because the gear targets multiple species of sharks, and is not used in association with ICCAT. However, the outcome is the same; those using this equipment are retaining sharks that are declining in population and in need of protection. The rule only restricts the method used to capture sharks, meaning the number of endangered sharks being fished will likely be reduced, but there’s still no limit to how many of these sharks can be retained. Although methods of fishing that target many kinds of sharks make it difficult to control which kinds are taken on board, the rule could extend to these kinds of fishing as well. If 55 percent of hammerhead sharks are still alive when brought on board a vessel in connection with ICCAT fishing — sharks caught by other methods are likely brought on board alive as well. Placing restrictions on ICCAT fishing will only address part of the problem. Alternative 3 in the rule only prevents recreational and commercial fishermen from retaining the sharks, and the rule states that there are no recorded instances of such fishermen doing so. This is simply a way to technically implement ICCAT shark recommendations, but it would do little to preserve the species, which is the goal of the rule.