Since 1970, dusky shark populations have declined by 99%. Sharks are the most powerful predators in the ocean, but millions of years of evolution did not prepare them for the increasing number of hooks and nets that are killing them. Sharks are particularly vulnerable to overfishing because they mature slowly and only have a few young at a time. According to a 2007 study in the journal Science, decades of overfishing of Atlantic sharks, like the dusky shark, caused the collapse of the U.S. shellfish industry.
With the disappearance of Atlantic sharks, their former prey cownose ray populations have grown tenfold. Scallops are a central part of the rays' diet. The study shows that the population boom of cownose rays put an end to North Carolina's century-old Bay scallop fishery in 2004. Without a recovery of Atlantic sharks, researchers fear the migrating rays will consume U.S. shellfish populations beyond recovery.
The dusky shark is just one of 48 federally-managed fish stocks that were damaged by overfishing in 2006. Reckless overfishing continues to put our fish, shellfish, birds, marine mammals, and all of ocean life at jeopardy. The National Marine Fisheries Service is taking public comments as it revises its rules for overfishing and environmental review.
Fish populations are collapsing in America's oceans with tragic impacts for all of ocean life. According to a 2007 study in the journal Science, decades of overfishing of Atlantic sharks including dusky sharks led to the collapse of the U.S. shellfish industry. The loss of sharks as top predators led to an explosion of the cownose ray population which then decimated the scallops. Despite this damage, your agency reports that dusky sharks were one of the 48 fish stocks harmed by overfishing in 2006. The need for a precautionary ecosystem approach to fishery management is long overdue.
This process began because Congress and the President recognized a crisis in the oceans and passed a decisive law to end overfishing and elevate the role of science in fisheries management. Your final new National Standard 1 must be strong and clear to ensure that Fishery Management Councils err on the side of caution in setting annual catch limits and accountability measures. America's oceans are publicly owned. As one of those owners, I want a new National Standard 1 that ends overfishing of all stocks, including the dusky shark, as required by law.
Congress also directed your agency to review and update its environmental review procedures to ensure compliance with all existing National Environmental Protection Act (NEPA) requirements. The dusky shark is a powerful example of how fishery management depends on a broader understanding of ecosystem impacts. We must look at more than fish, and consider relationships with other species like scallops and the industries which depend on them that are impacted by fishery management decisions. Your review of the impacts of fishing on specific stocks must include public comments like this one, a thorough public consideration of alternatives, and an analysis of the broader ecosystem impacts.
Thank you for your work. Please consider this an official comment for proposed National Standard 1 and proposed NEPA regulations.
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