Comment from Borys Jr, John

To Whom It May Concern, I am writing to express my strong opposition to the proposed increases in shark harvest flexibility and retention limits under the current Atlantic shark fisheries rulemaking. I urge NOAA Fisheries to continue following a precautionary, science-based management approach and reject measures that could reverse decades of difficult shark conservation progress. Recent calls to loosen shark regulations are being driven largely by anecdotal complaints regarding shark depredation from segments of the recreational and commercial fishing industries. However, increased depredation should not automatically be interpreted as evidence of an “overpopulation” of sharks. Depredation is a predictable ecological consequence of recovering predator populations interacting with heavily pressured fisheries in increasingly crowded marine environments. For decades, many fishermen operated during a period when shark populations had been severely depleted by overfishing. What some fishermen now perceive as an abnormal increase in shark encounters may instead reflect a partial return toward ecological balance after historic predator collapse. Management decisions should not be driven by frustration or perception alone, particularly when dealing with long-lived apex predators that are inherently vulnerable to overexploitation. Facts: • Many shark species remain far below historical population levels despite recent rebuilding progress. Numerous Atlantic species experienced population declines exceeding 70 percent during the late 20th century due to targeted fishing, bycatch, and finning pressure. • Sharks are among the slowest recovering marine fish species. Many large coastal and pelagic sharks mature late, produce few offspring, and have long gestation periods. This makes them exceptionally vulnerable to even moderate increases in fishing mortality. • Apex predators are essential to healthy marine ecosystems. Sharks help regulate prey populations, remove weak and diseased animals, and stabilize food-web dynamics. The loss of apex predators has been linked in scientific literature to trophic cascades and destabilized fisheries ecosystems worldwide. • Shark depredation is not occurring in isolation. It is occurring alongside increasing fishing effort, advanced fish-finding technology, expanding offshore recreational pressure, and continued depletion of many forage and sportfish populations. Increased competition for fish resources naturally increases predator interactions. • Scientific uncertainty should favor conservation, not expanded harvest. NOAA’s own fisheries management framework traditionally recognizes that uncertainty in stock assessments, climate impacts, and ecosystem shifts requires precautionary management rather than increased exploitation. • Climate change and habitat degradation are already placing additional stress on shark populations. Ocean warming, shifting prey distribution, coastal habitat loss, and declining water quality all compound fishing mortality and reduce ecosystem resilience. • Expanding harvest opportunities increases the risk of bycatch mortality and enforcement complications involving prohibited or vulnerable species, including hammerheads, oceanic whitetips, and juvenile sharks that are difficult to identify at sea. Sustainable fisheries management must be based on rigorous peer-reviewed science and long-term ecosystem health—not short-term economic pressure or public perception. Rather than increasing harvest flexibility, NOAA should focus on: • Improved scientific monitoring and stock assessments • Better bycatch reduction technologies and handling practices • Angler education regarding depredation and ecosystem recovery • Protection of critical nursery and pupping habitats • Ecosystem-based fisheries management that accounts for predator-prey dynamics The recovery of shark populations should be viewed as evidence that conservation measures are working, not as justification to weaken them. Healthy shark populations are essential to resilient oceans, sustainable fisheries, and the long-term economic future of coastal communities. Thank you for your time, consideration, and dedication to protecting our nation’s marine ecosystems. I strongly urge NOAA Fisheries to reject proposals that would increase shark harvest pressure and instead continue advancing precautionary, science-based shark conservation and management. Sincerely, John Borys