May 27, 2026
Attention: Highly Migratory Species Management Division (F/SF1)
National Marine Fisheries Service (NMFS)
Re: Revisions to Commercial Atlantic Blacknose and Recreational Atlantic Shark Fisheries Management Measures; Proposed Rule
Submitted by: Shark Stewards
To Whom It May Concern,
On behalf of Shark Stewards, a non-profit marine conservation organization dedicated to protecting global shark populations and maintaining healthy ocean ecosystems, we submit these comments strongly opposing the proposed revisions to the commercial Atlantic blacknose and recreational Atlantic shark fisheries management measures.
As detailed in our public position (see Shark Stewards: NOAA Proposes to Increase Atlantic Shark Fishing), this proposed rule represents a dangerous step backward for shark conservation in the northwestern Atlantic, Gulf of Mexico, and Caribbean. NMFS is attempting to dismantle hard-won boundaries, raise recreational bag limits (including up to three or no limits on specific trips for vulnerable species like hammerheads), and alter minimum size requirements. We urge the agency to reject these revisions, which lack scientific justification, bypass critical stock assessments, and directly threaten highly vulnerable apex predators.
We oppose this proposal based on the following critical flaws:
1. Absolute Lack of Up-to-Date, Peer-Reviewed Stock Assessments
To manage any fishery sustainably under the Magnuson-Stevens Act, management actions must be predicated on robust, peer-reviewed data. Alarmingly, the majority of the shark species targeted for increased retention limits under this proposal completely lack formal, current population assessments.
For instance, the Atlantic blacknose shark (Carcharhinus acronotus) is highly vulnerable to overfishing, with its East Coast population already decimated by more than half over the past 25 years. Erasing management boundaries or increasing quotas for the commercial blacknose fishery without a fresh baseline stock assessment violates the precautionary principle of marine resource management and risks triggering a rapid population collapse.
2. Anecdotal Reports Cannot Replace Empirically Validated Science
The primary justification provided for this proposal relies heavily on anecdotal reports from commercial and recreational fishermen claiming a localized “overabundance” of sharks interfering with catches. Anecdotes are not science.
A spike in human-shark interactions in specific, concentrated areas does not equate to a healthy or booming regional population. By substituting real data with localized complaints, NMFS is abandoning its mandate to base Highly Migratory Species (HMS) management on the best scientific information available.
3. Misinterpretation of Climate-Driven Shifting Baseline Dynamics
The localized aggregations reported by fishermen are better explained by shifting prey patterns and changing marine environments than a true population recovery. Due to rising ocean temperatures and severe marine heatwaves driven by climate change, Atlantic sharks are shifting where they migrate, forage, and feed.
Sharks are moving into new territorial pockets seeking cooler waters, concentrating them in areas where fishing pressure is high. Mistaking these climate-induced behavioral shifts for “overpopulation” is an egregious ecological error. NMFS must analyze how climate change impacts these species’ movements before opening the floodgates to higher catch limits.
4. Severe Biological Threats to Hammerhead and Other Shark Species
The proposal to relax recreational bag limits—potentially allowing up to three or no limit on certain trips for hammerhead sharks—places exceptionally vulnerable species in severe jeopardy. Hammerheads are slow-growing, long-lived apex predators that feature low reproductive outputs. They simply cannot reproduce fast enough to withstand elevated recreational slaughter.
Furthermore, while the proposed changes alter minimum size limits, the new baseline of 54 inches for species like blue sharks, common threshers, and porbeagles completely defies biological reality. The average female size at maturity for these species is vastly higher: approximately 75 inches for blue sharks, 85 inches for threshers, and 86 inches for porbeagles. Setting a catch limit at 54 inches legalizes and encourages the harvest of juveniles before they have a single chance to reproduce, threatening these populations with localized extinction.
Conclusion
With over one-third of all global shark and ray species currently facing extinction risks, NMFS should be strengthening protections, not weakening them on behalf of commercial and recreational fishing interests. Stripping away protections from vulnerable species in the absence of peer-reviewed science is a failure of federal stewardship.
Shark Stewards strongly demands that NMFS reject these revisions. No management changes, boundary removals, or quota increases should be enacted without comprehensive, up-to-date stock assessments and size limits that align accurately with female biological maturity.
Thank you for considering these comments.
Sincerely,
David McGuire, Director
Shark Stewards