Stop overfishing of South Atlantic blueline tilefish

What the public could have raised, from the agency’s own document

• I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
• The agency abandons any effort to reconcile a fundamental inconsistency in its own recreational data, treating two different measurement systems (CHTS vs. FES) as 'roughly equivalent' without quantitative justification. Section 1.3.3 states the recreational ACL 'would increase from 116,820 lbs ww (inclusive of CHTS estimates) to 156,809 lbs ww (inclusive of FES estimates)' and that 'the change in how the ACL is being accounted for due to the switch from CHTS to FES estimates is considered to be roughly equivalent.' Tables 1.3.4 and 1.3.5 show these two data streams produce wildly divergent estimates: FES data in Table 1.3.5 reports landings 2 to 14 times higher than CHTS data in Table 1.3.4 for the same years. The agency provides no analysis of why a 33,000+ pound increase should be treated as having no biological or economic significance. The agency should quantify the actual…
• The agency's discard estimate—a critical input to the total ACL calculation—is derived from a sub-region (North Carolina north of Cape Hatteras) not provided in the original assessment. Section 1.3.1 states: 'This sub-region information was already available in SEDAR 92, but was not provided in the assessment report.' The agency then extracted this unpublished data, averaged it over seven years, and applied it to set a 12,742-pound discard deduction (3.9% of ABC) with no explanation of why seven-year averaging was appropriate or whether the assessment scientists concurred. The agency should justify why unpublished sub-regional data was used instead of the regional discard estimates presented in the final assessment, and provide the underlying discard data and methodology for public review.
• The sector allocation decision appears contradictory and unreasoned. Section 1.4 states the South Atlantic Council 'determined that the overall benefit to the fishery of quickly implementing the increased ABC is greater than potential benefits of waiting for a more prolonged process that would include re-evaluating sector or regional apportionment percentages' and applied the existing 50.07% commercial / 49.93% recreational split. However, the Council's own footnote 5 documents preliminary sector ACL estimates that would result from 'recent SSC recommendations presented to the South Atlantic Council in September 2025.' The agency provides no analysis of what those preliminary estimates were, why they differ from the chosen allocation, or what the quantified trade-offs are. The agency should disclose the alternative sector allocations that were analyzed and explain the scientific and…
• The agency's treatment of the OFL as 'unknown' creates an unresolved tension with overfishing determinations. Section 1.3.1 states 'Data-limited approaches do not produce overfishing level (OFL) estimates, so the OFL for blueline tilefish is unknown.' Yet the entire management framework depends on preventing overfishing. The document provides no analysis of whether and how accountability measures will function when the overfishing threshold itself is undefined, or what mechanism prevents the ACL from drifting toward overfishing in future years if landings increase. The agency should explain how the MSA's overfishing prevention mandate can be satisfied when the OFL is unknown, and specify what monitoring or trigger points will prompt a reassessment.