July 8, 2002

The Honorable Walter B. Jones, Jr.
U.S. House of Representatives
422 Cannon House Office Bldg.
Washington, DC  20515
 

Dear Congressman Jones:

Thank you for your request to Blue Water Fishermen’s Association to provide the following important information that reveals the actual impacts of the Saxton Amendment recently adopted by the Committee. Blue Water Fishermen’s Association represents the majority of the US longline fishing industry including those vessels directly affected by the Saxton Amendment.

A fundamental objective of United States fishery conservation and management policy and law is to maximize conservation benefits while minimizing adverse economic impacts on fishermen and fishery-dependent communities.  The Saxton Amendment will have precisely the opposite result. 

The Saxton Amendment will minimize if not reverse the conservation of Atlantic white marlin. 

· At best, the Saxton Amendment will have no meaningful or measurable impact on Atlantic white marlin conservation.  For this reason, NMFS has concluded that the Saxton Amendment time-area closures will have no effect on the decision on whether to list Atlantic white marlin under the Endangered Species Act.  The average annual longline bycatch mortality of Atlantic white marlin in the Saxton Amendment time-area closures is less than one-half of one percent of the total of such mortality reported to ICCAT.  More than 99.5 percent of longline fishing white marlin mortality occurs outside of the Saxton Amendment time-area closures.  This conclusion is based on the comprehensive analysis of NMFS data.

· At worst, the Saxton Amendment will result in an increase in Atlantic white marlin mortality.  On average, a white marlin is killed in the Mid-Atlantic pelagic longline fishery once every sixteen days of fishing. The Saxton Amendment will force a shift of US longline fishing effort from this area where the rate of Atlantic white marlin and blue marlin bycatch (as measured by the catch per unit of effort) is one of the lowest in US waters, to areas where the rate of Atlantic white marlin and blue marlin bycatch is higher.  As a result, it is likely that the Saxton Amendment will cause more white marlin to be killed.  This conclusion is based on the comprehensive analysis of NMFS data.

· These closures are not based on scientific information nor designed to prevent the catches/mortality of Atlantic white marlin, but rather to enable the catches/mortality of Atlantic white marlin by wealthy sportfishermen.  NMFS’s data show that the Mid-Atlantic Bight is not the area within the EEZ with the greatest discards of white marlin by pelagic longline fishermen.  The faulty perception that U.S. pelagic longline fishermen in the Mid-Atlantic Bight are causing reduced catches of Atlantic white marlin by sportfishermen in the Mid-Atlantic Bight is unfounded and easily disproved by the high catches of recent tournaments in the area.

· The destruction of the US pelagic longline fishery will also have a substantial negative bycatch and directed species conservation consequence in itself.  The loss of the US Atlantic pelagic longline fishery will simply cause ICCAT to reallocate the unused US quotas of swordfish and tunas to large fishing nations such as Spain and Japan or smaller newcomers such as Brazil or Namibia.  With perhaps the exception of the small Canadian pelagic longline fleet, virtually every other major Atlantic pelagic longline fishing nation has a conservation, bycatch and compliance record that is disgraceful—especially in comparison to the US industry’s record.  More quota for nations like Spain and Namibia means more pelagic longline fishing effort by Spain and Namibia.  More fishing effort by those nations means much greater bycatch mortality of small swordfish and billfish and substantially reduced conservation for swordfish and tuna.

The impacts of the proposed closures are very significant.  They cannot be dismissed with the simplistic conclusion that fishermen can just go fish in the “open” areas.  No fisherman can go just anywhere in the ocean, put their fishing gear in the water and catch fish.  It’s a little more complicated than that.  The oceanographic currents and features, combined with submarine topography, determine where fishing is likely to be successful.  In the Mid-Atlantic Bight area, productive fishing usually occurs along the edge of the continental shelf, in the canyons situated 80-100 miles east of the coast.  When the Gulf Stream fingers and eddies cross the Mid-Atlantic Bight canyon areas, the concentrations of swordfish, tunas and sharks enable our fishermen’s hook-based gear to catch enough to sustain their livelihoods. 

These are precisely the areas proposed for closure by the Saxton Amendment, but it is impossible to predict in which of the two closed areas such oceanographic features and productive fishing will occur at any given time during these summer months.  The availability of highly migratory species and profitable edges of water, thus the dependent fisheries, are quite cyclic.  Single year “snapshots” are deceiving and promote an inaccurate long-term perspective.

These are the fallacies of the “rolling closure” concept.

For example, during high production cycles for swordfish, tunas and sharks, the pelagic longline fishery contributes as high as 50 to 60% of the total business to area docks, fish dealers and related supply/service businesses.  During a low productivity cycle, this may be only 20 to 30% of the total area fisheries economics.  However, as Ms. Jean Podinsky, accountant for Lighthouse Marina (one of two commercial landing facilities) and past President of the local Taxpayers Association, reminded everyone in 2000, “Even though both the commercial and recreational revenues are critical to the overall economics of these businesses and this town, it is the year-round nature of the commercial fishery that provides the revenues and employment opportunities that sustain the year-round economy of Barnegat Light.  The commercial docks also provide a majority of the tax-base for the entire borough.  The important summer season recreational and commercial revenues are not enough for this town.”  It is the year-round revenues from the commercial fishery which provide the year-round jobs that support the overall economy of Barnegat Light and similar coastal commercial fishing communities.  This year-round characteristic is unique among most seaside resorts that typically only sustain a seasonal economy.

· The Saxton Amendment time-area closures, and the Mid-Atlantic Bight area generally, represent some of the most productive longline fishing grounds for tuna, swordfish and other targeted species in the Atlantic ocean.  In fact, US longline fishermen achieve the highest rate of target species catch (as measured by catch per unit effort) in this area as compared to any other area in Atlantic US waters.  Closing these areas will maximize the economic impact on US longline fishermen.  This conclusion is based on the comprehensive analysis of NMFS data.

· The Saxton Amendment time-area closures encompass nearly all of the productive fishing areas in the Mid-Atlantic Bight.  US longline fishermen catch an average of 6-9 million pounds of tuna, swordfish and other target species each year in the Mid-Atlantic Bight for which they are paid $15-27 million. 

· For every Atlantic white marlin incidentally killed by longline fishing in the Mid-Atlantic Bight (Saxton Amendment time-area closures), US longline fishermen catch an average of about 18,274 pounds of tuna, swordfish and other high-quality fish for US consumers for which they are paid $ 65,714.   This conclusion is based on the comprehensive analysis of NMFS data.

North Carolina:

There are approximately 20 active pelagic longline vessels operating out of North Carolina.  They range in size from smaller weekly-trip vessels to medium 2-3 week trip vessels.  These fishermen make at least 75% of their sets in the proposed closed areas.

Each of these 20 vessels carry a crew of 3-5 crew for total employment of 60-100 onboard.  Adding to that is the factor of 10 that NMFS uses for estimating shoreside support employment for each vessel.  Therefore, the total employment directly associated with North Carolina longline fishery is approximately 260-300 jobs directly impacted in North Carolina area.

Furthermore, each of these 20 vessels generates an average of $300,000.00 - $400,000.00 in annual gross income.  Thus, the total annual gross income generated by these vessels is $6-8 million. 

New Jersey:

There are 23-26 active pelagic longline vessels operating out of New Jersey.  They are of slightly larger average size than the North Carolina vessels.  Most are 2-3 week trip vessels.  These fishermen make at least 75% of their fishing sets in the proposed closed areas.

Each of these 25 vessels carry a crew of 4-5 crew for total onboard employment of 100-125.   Adding to that is the factor of 10 that NMFS uses for estimating shoreside support employment for each vessel.  Therefore, the total employment directly associated with New Jersey longline fishery is approximately 350-375 jobs directly impacted in New Jersey area.

Furthermore, each of these 25 vessels generates an average of $350,000.00 - $450,000.00 in annual gross income.  Thus, the total annual gross income generated by these vessels is $8.7 to $11.3 million. 

The following table demonstrates the universe of potentially-impacted permit holders as provided by NMFS as of April 2002.
 
 

State	Total Swordfish or Shark permit holders	Swordfish Directed Permit holders	Pelagic longline gear as primary type
New York	30	16	12
New Jersey	64	32	21*
Delaware	2	2	1
Maryland	11	8	8
Virginia	7	1	1**
North Carolina	24	8	8
TOTAL	138	67	51

   *Four vessels are fishing either in the Pacific or South Atlantic Oceans, not in the Mid-Atlantic Bight.
** One vessel is damaged and not fishing; this vessel primarily fished along the east coast of Florida before the closures in 2001. 

Additional points to consider:

· By closing areas, the Saxton Amendment will force 100% of the effort into the remaining open areas.  This will undoubtedly result in unwanted and unforeseen circumstances.  Sportfishermen will be just as displeased when they encounter more than double the number of pelagic longline fishermen fishing within view during the time when “their” area is open.  In addition, during the August 15-August 31 period when both areas are closed, all pelagic longline fishermen in this area will have no choice but to fish off North Carolina or eastern Long Island, NY. 

· If Mid-Atlantic pelagic longline fishermen cannot use their preferred fishing gear, they may choose to “sit” in the productive canyons and use “chunking”, “greenstick” and/or “handline/handgear” fishing methods to fish for swordfish and tunas.  They will likely need to stay out on the fishing grounds even longer than they do now.  These other types of “hook and line” fishing are likely to catch more white marlin than pelagic longline fishing.

· The pelagic longline fishermen in the Mid-Atlantic Bight are already suffering under a so-called “Bluefin tuna closure” that closes a large area south of Long Island for the entire month of June.  If the proposed closures go into effect, the most productive area of fishing in the northwestern Mid-Atlantic Bight will be open for only two weeks and then closed again until September.  The cumulative impact of such closures, especially back-to-back closures is enormous, especially considering the short timeframe when highly migratory species are available in this area.

· The small but important northern large coastal shark fishery will be decimated, as its quota opens on July 1 each year and generally only lasts for 3-8 weeks until closed, depending on effort and catches. 

· The pelagic longline fishermen and their associated businesses in the Mid-Atlantic Bight depend on the fairer weather during the summer and early autumn months to provide the income needed to sustain them through the poor weather months from December to May.  The months of June through October represent 75% of the fishing done by pelagic longline fishermen in the Mid-Atlantic Bight, with more than 51% occurring in the months of July through September.  A closure at this time will push these fishermen and their dependants, both families and related service/suppliers, over the edge.

We hope that this helps to explain why this legislation and other efforts to close areas in the Mid-Atlantic Bight or otherwise progressively dismantle the US pelagic longline fishery is a bad idea.  It’s bad for tuna and swordfish conservation, it’s bad for marlin and sailfish conservation, and it’s bad for US fishermen and the American communities in which they live.

Thank you for the opportunity to explain the potential damage and consequences of the proposed closures in the Mid-Atlantic Bight.  We appreciate all your assistance in trying to prevent its adoption.

Sincerely,
 

Nelson R. Beideman
Executive Director
Blue Water Fishermen’s Association