Comment from Borys, Donna

To Whom It May Concern, I am writing in opposition to the proposed changes to Atlantic shark management measures that would increase harvest flexibility and retention opportunities for shark species in Florida and the broader Atlantic region. Current concerns regarding shark depredation in Florida fisheries should not be used as justification for weakening precautionary shark management. Increased shark interactions are occurring alongside increasing recreational fishing pressure, expanding use of fish-finding technology, and continued stress on reef and pelagic fish stocks. These interactions do not constitute scientific evidence that shark populations have fully recovered or can sustain substantially increased harvest pressure. NOAA Fisheries has previously determined that several Atlantic shark species required rebuilding plans to end overfishing, including Atlantic blacknose sharks, scalloped hammerheads, and dusky sharks. (NOAA Fisheries) Atlantic blacknose sharks remain classified by NOAA as overfished, with rebuilding efforts extending through 2043. (NOAA Fisheries) Sharks possess life-history traits that make them exceptionally vulnerable to overexploitation, including slow growth, late maturity, and low reproductive output. Scientific literature has consistently demonstrated that depletion of apex predators can destabilize marine ecosystems and alter food-web structure. Research by Myers et al. (2007) documented trophic cascades associated with large shark declines in the northwest Atlantic, while Heithaus et al. (2008) emphasized the ecological importance of sharks in maintaining healthy marine ecosystems. Florida waters are a globally important habitat for coastal and migratory shark species, including blacktip sharks, hammerheads, lemon sharks, tiger sharks, and blacknose sharks. Increasing harvest flexibility in these waters risks undermining decades of conservation progress at a time when climate change, habitat degradation, and warming oceans are already placing additional stress on marine ecosystems. Rather than increasing harvest opportunities, NOAA should prioritize: • Continued precautionary management of rebuilding shark stocks • Improved monitoring and stock assessments • Research into nonlethal depredation mitigation measures • Enhanced angler education and safe-release practices • Protection of critical nursery and pupping habitats in Florida waters The recovery of shark populations should be viewed as evidence that existing conservation measures are working—not as justification to weaken them prematurely. Thank you for considering these comments and for continuing to rely on science-based fisheries management to protect the long-term health of Atlantic marine ecosystems. Sincerely, Donna Borys References: Heithaus, M.R., Frid, A., Wirsing, A.J., & Worm, B. (2008). Predicting ecological consequences of marine top predator declines. Trends in Ecology & Evolution, 23(4), 202–210. Myers, R.A., Baum, J.K., Shepherd, T.D., Powers, S.P., & Peterson, C.H. (2007). Cascading effects of the loss of apex predatory sharks from a coastal ocean. Science, 315(5820), 1846–1850.