Comment from Shark Stewards

Attention: Highly Migratory Species Management Division (F/SF1) National Marine Fisheries Service (NMFS) Re: Revisions to Commercial Atlantic Blacknose and Recreational Atlantic Shark Fisheries Management Measures; Proposed Rule Submitted by: Shark Stewards To Whom It May Concern, On behalf of Shark Stewards, a non-profit dedicated to protecting global shark populations and healthy ocean ecosystems, we strongly oppose the proposed revisions to commercial Atlantic blacknose and recreational Atlantic shark fisheries management measures. As detailed in our public position, this proposed rule represents a dangerous step backward for shark conservation in the northwestern Atlantic, Gulf of Mexico, and Caribbean. NMFS is attempting to dismantle hard-won boundaries, raise recreational bag limits (including up to three or no limits on vulnerable species like hammerheads), and alter minimum size requirements. We urge the agency to reject these revisions, which lack scientific justification, bypass critical stock assessments, and directly threaten vulnerable apex predators. We oppose this proposal based on the following critical flaws: 1. Absolute Lack of Up-to-Date, Peer-Reviewed Stock Assessments To manage fisheries sustainably under the Magnuson-Stevens Act, actions must be predicated on robust data. Alarmingly, most shark species targeted for increased retention limits completely lack formal, current population assessments. The Atlantic blacknose shark is highly vulnerable to overfishing, with its East Coast population decimated by over half in the past 25 years. Erasing boundaries or increasing quotas without a fresh baseline stock assessment violates the precautionary principle and risks triggering a rapid population collapse. 2. Anecdotal Reports Cannot Replace Empirically Validated Science The primary justification for this proposal relies heavily on anecdotal reports from fishermen claiming a localized "overabundance" of sharks. Anecdotes are not science. A spike in human-shark interactions in concentrated areas does not equate to a healthy regional population. By substituting real data with localized complaints, NMFS is abandoning its mandate to use the best scientific information available. 3. Misinterpretation of Climate-Driven Shifting Baseline Dynamics The localized aggregations reported by fishermen are better explained by shifting prey patterns and changing marine environments than true population recovery. Due to rising ocean temperatures driven by climate change, Atlantic sharks are shifting where they migrate and forage. Sharks are moving into new territorial pockets, concentrating them in areas where fishing pressure is high. Mistaking these climate-induced behavioral shifts for "overpopulation" is an egregious ecological error. NMFS must analyze how climate change impacts movements before raising catch limits. 4. Severe Biological Threats to Hammerhead and Other Shark Species Relaxing recreational bag limits—potentially allowing up to three or no limit on certain trips for hammerhead sharks—places exceptionally vulnerable species in severe jeopardy. Hammerheads are slow-growing, long-lived apex predators with low reproductive outputs. They cannot reproduce fast enough to withstand elevated recreational slaughter. Furthermore, while the changes alter size limits, the new baseline of 54 inches for blue sharks, common threshers, and porbeagles defies biological reality. The average female size at maturity is vastly higher: approximately 75 inches for blue sharks, 85 inches for threshers, and 86 inches for porbeagles. Setting a limit at 54 inches legalizes the harvest of juveniles before they can reproduce, threatening these populations with extinction. Conclusion With over one-third of global shark and ray species facing extinction risks, NMFS should be strengthening protections, not weakening them for fishing interests. Stripping away protections in the absence of peer-reviewed science is a failure of federal stewardship. Shark Stewards demands that NMFS reject these revisions. No management changes, boundary removals, or quota increases should be enacted without comprehensive, up-to-date stock assessments and size limits that align accurately with female biological maturity. Thank you for considering these comments. Sincerely, David McGuire, Director SharkStewards.org