Dear NMFS West Coast Regional Administrator Barry Thom,
It is deeply concerning that the National Marine Fisheries Service proposed a rebuilding plan for Pacific sardine that fails to rebuild this collapsed and overfished population. The proposed rebuilding plan would simply continue status quo management, which we know is not working. The plan as proposed does not contain meaningful measures to rebuild the collapsed sardine population and it ignores the best available science. In fact, the agency’s own analysis shows the proposed rebuilding plan will not only fail to recover the sardine population, it may also drive it deeper into collapse.
The “status quo” proposal must be rejected. It undermines the requirements of the Magnuson-Stevens Fishery Conservation and Management Act to rebuild overfished populations in as short a time as possible. The proposed rebuilding plan also puts at risk the myriad fish and wildlife that depend on sardines for food. Pacific sardine are an incredibly important food source for marine mammals, seabirds, and other fish, including threatened and endangered humpback whales, sea lions, brown pelicans, sharks, and salmon.
Please reject the proposed rebuilding plan and instead adopt and implement Alternative 3. Alternative 3 limits U.S. sardine catch to no more than 5% of the total sardine population beginning July 1, 2021. This approach would reasonably allow some catch, while simultaneously establishing limits strong enough to rebuild the Pacific sardine population back to healthy and productive levels within the legally required timeline. Taking a precautionary course of action better reflects the best available science indicating historically low sardine productivity and will help ensure our fisheries are resilient to climate change.
Thank you again for the opportunity to comment on this important issue.