DSF comment on Porbeagle Shark ESA Listing Petitions

Directed Sustainable Fisheries, Inc. (DSF) submits scientific information about the Northwest (NW) Atlantic Ocean Porbeagle shark (Lamna nasus) distinct population segment (DPS) status that was not properly addressed in the two petitions from the Wild Earth Guardians (WEG) and the Humane Society of the United States (HSUS) dating from 2010. The March 27, 2015 Federal Register request for information was to ensure a comprehensive review you are soliciting scientific and commercial data and other information relevant to the status of porbeagle sharks worldwide. DSF wants the information we are providing to assist the NMFS to find that a listing is not warranted on or before December 12, 2015.

When the WEG and HSUS petitions were originally filed the actual porbeagle shark pupping (birthing) grounds for the NW Atlantic Ocean DPS was not publicly known. On November 16, 2009 a study was received, then on March 01, 2010 accepted, and published March 30, 2010 on the NRC Research Press Web site about porbeagle sharks pupping grounds authored by Campana et al1. They were using pop-up archival transmission tags that proved the mature female porbeagle sharks were traveling south to the sub- tropical waters of the Sargasso Sea in the Central Atlantic Ocean to give birth to their pups. As noted by the authors in the abstract this “…key life history stage in international, largely unregulated waters poses problems for the conservation and management of a species that is largely fished in Canadian waters.” It is not unreasonable to assume that the other distinct population segments of mature female porbeagle sharks in the Northeast Atlantic Ocean, and the Mediterranean Sea could demonstrate similar behavior.

The Campana et al NW Atlantic Ocean DPS porbeagle shark stock assessment2 was completed during 2009, and dated in the collection by ICCAT3 as 2010. That assessment was used by the NMFS to manage the US porbeagle shark fishery. The authors state on PDF page 4 (page 2112) in the assessment report, Section 2.4 titled “Porbeagle reproduction” that “The location of the pupping ground remains unknown.” That statement raises a red flag with DSF clients because some of the authors did know since April 2008 through to July 2009 that the pop-up archival transmission tags indicated that several mature female porbeagle sharks were in the Sargasso Sea region at the end of the pupping cycle. See Table 1 in the subtropical pupping ground report for the accurate dates and locations. The secured document will not allow for the table to be pasted in this comment and the hyperlink is provided in the first footnote above. The two Campana et al reports will be uploaded along with the DSF written comment on the www.regulations.gov web page dedicated for this status review.