Comment from Trbovich, Stephen

The following are my comments on the proposed commercial and recrational measures. Blacknose Shark Management Boundary in the Atlantic Region: I support the removal of the Atlantic latitudinal boundary for blacknose sharks (preferred Alternative A2) in light of recent findings on seasonal distribution (Ahr et al. 2025). Blacknose Shark Commercial Retention Limit in the Atlantic Region: I support Alternative B1; per current NMFS data the Atlantic blacknose shark fishery is overfished and experiencing overfishing. This does not support an increase in retention limits from eight to 60; a flexible range based on fishery trends with a maximum retention limit of 25 is more prudent. Commercial Management Group Quota Linkages: I oppose the proposed changes as these serve as a useful tool to limit bycatch and overfishing of sensitive species such as hammerheads. Recreational Minimum Size Limits: Although a proposed move to species-specific size limits as outlined in Alternatives C2-C5 would improve management, the proposed default sizes do not reflect size at maturity for a number of the species included, and the provision to remove any size limits is troubling. Recreational Retention Limits: This is perhaps the most troubling proposal, and I oppose the proposed changes for the following reasons: *A number of the included species, such as thresher sharks, do not have current stock assessments, leaving the impact of increased recreational take limits uncertain. Other species are currently listed as overfished, making increases irresponsible. *Recreational data reporting still has a number of gaps, including species identification and catch reporting. This runs the risk of increased retention limits causing more damage before corrective management actions can be implemented. *The option to remove limits entirely should not be on the table at all; this would allow a complete open season without public consultation. Overall, I am concerned that the proposed recreational fishing changes are less driven by economic considerations than external pressure to “do something” about the perceived “overpopulation” of sharks. The number of comments citing a 10-year timescale where this “problem” has developed must be viewed in light of the long life cycles and low fecundity of the species in question and the severe damage done to Atlantic and Gulf shark populations during the free-for-all years of the 1980s through the mid-1990s prior to NMFS instituting any sort of regulatory limits on shark fishing. During the May 13 public comment webinar session one caller offered the perspective that in the 1960s shark depredation was simply considered part of fishing that had to be addressed with changes in technique. Comments by NMFS staff both in AP webinars and scientific conference presentations floating proposed increases in commercial and recreational retention limits as a means to address depredation are a misuse of fisheries stock management policy, and set a disturbing precedent for future management policies to be driven by agitation, pressure, and threats (“people are going to take matters into their own hands” being a staple of AP meeting comments) rather than data.