Dorothy Lowman, Chair

Pacific Fishery Management Council

1100 NE Ambassador Place, #101

Portland, Oregon 97220

Re: Agenda Item H.5: Drift Gillnet Management Plan including Hard Caps FPA

Dear Chair Lowman and Council Members:

As members of the sportfishing community, we write in support of the Council’s recent actions to clean up the drift gillnet fishery for swordfish in California and provide the following recommendations. Specifically, we believe the Council should hold the drift gillnet fleet accountable through use of hard caps and 100 percent monitoring while transitioning the fishery to actively tended and more selective gear types and deny any application to open a longline fishery.

The drift gillnet fishery catches several species of marine life that are ultimately discarded including recreationally important species like striped marlin. Drift gillnets are inherently nonselective and will have unintended interactions even with increased monitoring and management. Therefore, we encourage the Council to move away from drift gillnets and transition the fishery to more selective and actively tended gear types like harpoon and buoy gear.

We also write to express our concern with the Council considering the authorization of a longline fishery both outside and inside our Exclusive Economic Zone. Longlines are simply another indiscriminate form of fishing and are not the solution to the drift gillnet problem. Resources should not be focused on developing a new swordfish fishery that uses outdated and wasteful methods. Instead, the Council and NMFS should focus their resources on transitioning to more selective and actively tended fishing gears.

As long as the drift gillnet fishery exists, we ask the Council to hold the fleet accountable. We support the Council’s implementation of hard caps on protected and vulnerable species, and 100 percent monitoring to ensure those hard caps are adequately enforced. Since the capture of some species is a relatively infrequent event, the Council needs to  have a clear picture of how many animals are caught by the drift gillnet fishery.  Enforcement of hard caps on protected species will not happen until every fishing trip is observed. We support the use of electronic monitoring, but only if it is proven to be as effective as onboard observers. Until electronic monitoring is available, the Council should impose 100 percent observer coverage.

Thank you for your consideration of these comments. As resource users, we look forward to working together toward sustainable management of our fisheries.

Sincerely,