34 



The key here is that the environmental organizations appear to be 

 targeting the sportfishing connnunity for membership contributions and 

 they seem willing to neglect the fact that estimates of recreational 

 landings for some of these HMS species exceed commercial longline 

 landings. If sport angler membership contributions were not an issue, 

 why would the major environmental organizations have taken the tack of 

 seeking additional protection for bluefin tuna through the Convention on 

 International Trade of Endangered Species (CITES) venue (which would only 

 limit commercial trade) rather than relying on the stronger U.S. 

 Endangered Species Act which would also restrict recreational activity 

 which annually kills more individual bluefin tuna than all commercial 

 users currently exploiting the assumed western North Atlantic stock? 



The coalition also neglects to reveal that, in some cases, NOAA's 

 inability to assess the status of some of these marine resources relates 

 directly to the absence of reliable estimates of the recreational catch 

 and size composition as well as bycatch of non-target species. While the 

 coalition supports fees and other legislative proposals that would 

 diminish commercial involvement in the process, we have not seen them 

 support any research efforts in the past two years that are not self- 

 serving or that relate directly to allocation discussions. The only 

 exception BWFA has encountered has been the Billfish Foundation, which 

 seems to place a greater emphasis on scientific data collection and is 

 willing to acknowledge and respect the livelihood commercial fishermen 

 have chosen. That organiz^ation has approached us constructively and we 

 have responded in kind. One of our members won their tagging award last 

 year and we are currently working cooperatively with them on a large- 

 scale double-tagging experiment which can provide invaluable biological 

 information. They apparently recognize that science-based management and 

 reasonable, practical approaches will produce results quicker than 

 confrontation. We have solicited "seed money" to support this tagging 

 effort from the environmental community; thus far, only the Audubon 

 Society has responded. 



Congress should review estimates of harvest levels by user group and then 

 compare these to the existing regulatory burden that supports current 

 management efforts. In particular, BWFA believes that the power and 

 influence of the sportfishing industry in the management process and 

 within NOAA is most clearly revealed by the almost complete absence of 

 permit and reporting requirements for charter, party, and headboats. 

 These small businesses reap the seme financial benefits that small family 

 commercial fishing businesses gain by having access to these offshore 

 resources. Our commercial fishing businesses have mandatory permits, 

 mandatory daily logs, mandatory dealer reports of sales and sizes of all 

 species caught, mandatory observer programs, and several other voluntary 

 research progreuns. The power and influence of the sportfishing lobby and 

 several others have made sure that NOAA has not established comparable 

 reporting and tracing progreuns for the recreational sportfishing 

 businesses. The emphasis here needs to be on businesses . How can the 

 Agency justify this in light of continued complaints that the marine 

 recreational fishing survey is not appropriate (nor effective) for 

 estimating landings of these HMS species? Even the existing minimum 

 estimates indicate that this user community in the Northeast may harvest 

 more yellowfin tuna than the entire commercial longline fishery off the 

 East Coast. How can the environmental community remain silent on this 

 issue and essentially support turning more and more of these resources 

 over to the U.S. user community that presents the greatest technical and 

 logistics problems for effective monitoring (including all bycatch), 

 enforcement, and compliance? The enviro-sportf ishing coalition has also 

 not addressed the continuing problems posed by the sale of so-called 

 "recreational" fish directly to restaurants. This underground economy 

 has supported overcapitalization of these fisheries and the volume of 

 sales undermines commercial markets. 



The building issue of bycatch is one that affects all fisheries for HMS, 

 commercial and recreational. It is most acute in the multi-species hook 

 and line fisheries. Eventually, you may come to the conclusion that to a 

 "fish" - a baited hook is a baited hook and it does not recognize the 

 political consequences of choosing whether that hook is at the end of a 

 commercial longline or at the end of a recreational rod and reel. BWFA 

 worked hard to provide the NMFS with East Coast Observer funds which were 

 to be used to cover all gear types interacting with HMS in all areas 

 during all seasons of the year. This Subcommittee should ask NMFS what 

 percentage has been used for observations outside of the pelagic longline 

 and gillnet fisheries? Our understanding is that no money has been spent 



