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TBF’S Official Comments to NMFS Amendment 15 Draft

The Billfish Foundation (TBF) made official comments to the National Marine Fisheries Service (NMFS) on Draft Amendment 15 to the Consolidated Highly Migratory Species (HMS) Fishery Management Plan.

We are extremely disappointed in the overly complex, technical, and lengthy presentation of the amendment, feeling as though the reader would need a Ph.D. in modeling fish population dynamics to fully comprehend the entire report. From the inclusion of PRISM instead of traditional fishery evaluations, to the combination of all billfish species into one generic grouping, TBF views this draft as an absolute failure and complete abuse of discretion.

Click below to review our full public comments on the Amendment 15.


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