Comment from Molly Lutcavage

Atlantic bluefin tuna (ABFT) are commercially valuable food fish consumed not just for sushi but also in sustenance diets of coastal residents of the Mediterranean and Northern Africa. ICCAT management seeks to rebuild Atlantic stocks, and scientists seek to fill in gaps in knowledge about ABFT including age of maturity, natal origin, growth and mortality. NOAA's policy of managing via "dead" or regulatory discards is outdated and needs to be done away with. This policy fails to serve economic, ethical and scientific needs. Regulatory discard of valuable fish defies conservation goals of sustainability and reduction of waste. And scientists need more access to "offshore" fish than is possible under current EFP's. In 2013, there should be a way for NOAA to use adaptive management and state of the art technologies to allow our fleet to catch the fish where the fish are most abundant and available, and not keep outdated control measures. Some may be based on inaccurate life history assumptions such as age of maturity. There should also be economic consideration of availability and distribution, and where fish are likely to be abundant, and therefore, more likely to be caught by US fishermen.