Support catch limits protecting Hawaii deepwater shrimp and coral
Pacific Island Fisheries; 2026-2028 Annual Catch Limits and Accountability Measures for Deepwater Shrimp and Precious Coral Fisheries in Hawaii
National Oceanic and Atmospheric Administration· HawaiiFederal Register 2026-15018 ↗
The groups on this fight
2 groups work Hawaii
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Friends of Hawaiʻi Volcanoes National Park
Works Hawaii: they work only in Hawaii.
- National Tropical Botanical Garden
Works Hawaii: hawaii is one of the 2 states they work in.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
These limits keep Hawaii's deepwater shrimp and precious coral from being fished beyond sustainable levels.
What’s at risk
Hawaii's deepwater shrimp populations and precious coral beds could be overharvested without enforced annual catch limits. If these protections are weakened or removed, there is no automatic correction when fishers exceed safe harvest levels.
If we stay silent
Catch limits stay in place through 2028, and any stock that is overfished automatically gets a reduced limit the following year to allow recovery.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
9 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I support this action and urge the agency to advance it.
- The document states that the deepwater shrimp fishery's average annual catch from 2019-2021 was 8,819 lb, representing only 3.5% of the proposed 250,773 lb ACL (Section 2.1.3.2). Yet the SSC calculated an ABC of 250,773 lb based on 91% of a 1988 MSY estimate of 275,575 lb with no new MSY data since then. The agency provides no analysis of why an MSY estimate from 35 years ago remains the best available science, nor explains the massive disconnect between recent catch trends and the ABC that purports to prevent overfishing. The document should justify reliance on 1988 data or conduct a new stock assessment to establish current MSY.
- For black coral, the Council recommended an ACL of 2,500 kg (5,512 lb), which is approximately 4,800 lb higher than the average annual landings of 697 lb from 2011-2021 (Section 2.2.2.1.3). However, the SSC-recommended ABC was 7,500 lb, nearly 2,000 lb higher still. The document states the Council 'did not recommend reducing the ACL from the ABC for social, economic, ecological considerations or management uncertainty' for deepwater shrimp (Section 2.1.2.3), but provides no explicit reasoning for why the Council reduced black coral's ACL below the SSC ABC without documented SEEM analysis. The agency should explain this departure from the ABC and whether SEEM factors were actually considered.
- The document acknowledges that an in-season accountability measure is infeasible because 'catch statistics are generally not available until at least six months after the data have been collected' (Section 1.2). This means the fisheries operate under post-season AMs only. Yet the document states 'NMFS does not expect the fishery to reach the ACL' for deepwater shrimp (Section 2.1.3.2) and similarly for precious corals. If catches are never expected to approach the ACL and post-season AMs cannot constrain mid-fishery overages, the ACL becomes purely symbolic with no actual management function. The agency should explain what protective function these ACLs serve if catches are expected to remain far below them and cannot be monitored in real time.
- For pink and bamboo corals in Established and Conditional Beds, the document states 'Fishing for pink and bamboo coral is not currently conducted in Hawaii' and 'the fisheries have been inactive' since 2001 (Sections 2.2.2.2 and 3.3.2.1). The agency is setting ACLs for fisheries with zero current participation and no harvest in over two decades. The document provides no analysis of what environmental or biological conditions would trigger these dormant fisheries to restart, no assessment of habitat or stock status for these corals, and no mechanism to evaluate whether reactivation would be sustainable. The agency should explain why it is establishing ACLs for fisheries with no data on current stock status and no apparent intent to resume operations.
Show all 11 points from the document
- The document states that 'There is no OFL estimate for deepwater shrimp in Hawaii' and 'There is no estimate of OFL for black coral in the Hawaii' (Sections 2.1.2.1 and 2.2.2.1.1). Yet the agency treats the 1988 MSY estimate as a proxy for OFL and calculates ABC as 91% of this proxy under the Tier 4 control rule. The Tier 4 rule is supposed to 'account for scientific uncertainty' (Section 1.1.2), but without an actual OFL estimate, the document provides no analysis of how much uncertainty exists or whether 91% of an unverified 35-year-old MSY adequately buffers against overfishing. The agency should conduct a formal analysis of the scientific uncertainty inherent in using an unvalidated 1988 MSY as an OFL proxy.
- The document states 'catch has never exceeded the ACL since NMFS began managing the fishery under ACLs in 2012' (Section 2.1.2.3). If a management tool has had zero constraining effect for over a decade despite being designed to prevent overfishing, the document should analyze whether the ACL is set appropriately or whether fishery conditions have fundamentally changed. Instead, the document merely rolls over the same ACL without re-examining whether the control rule or the MSY estimate should be updated. The agency should explain whether the absence of any ACL exceedances in 12 years indicates the ACL is ineffective, the fishery is truly moribund, or management assumptions require revision.
- The document acknowledges that 'Gear loss is a common problem' in the deepwater shrimp fishery, with 'Gear is estimated to be lost at a rate of 3.35% from fishing log data in Hawaii' (Section 3.2). Lost traps may cause 'snagging and ghost fishing' but the document states 'There is little information available on the impacts of the lost shrimp fishery traps on habitat and other species' (Section 3.2). The document then concludes with no further analysis: 'In the future and as data availability allows, NMFS and the Council will evaluate whether the impacts from lost traps are substantial and need to be addressed through additional management measures.' This defers a potentially significant habitat impact to the future without conducting current analysis. The agency should prepare an analysis of trap loss impacts before approving ACLs that could increase fishing effort and trap deployment.
- The document states that for black coral, 'Most of the harvest has come from State of Hawaii waters; however, a portion of the black coral bed in the Auau Channel is located in Federal waters' (Section 2.2.2.1). It then reports that '85% of the black coral harvested is hand-harvested by scuba divers within three miles of the shoreline' (Section 3.3.1.3.1). Since most harvest occurs in state waters and the Federal ACL is set at 5,512 lb while average Federal landings are unknown (data confidential), the document provides no analysis of how much of the proposed Federal ACL is actually harvested from the Federal portion of the Auau Channel Bed versus state waters. The agency should provide a clear accounting of the Federal versus state water landings and set Federal ACLs based on Federal water catch, not aggregate bed productivity.
- The document states that under the post-season AM, 'if NMFS and the Council determine that the average catch from the most recent three-year period exceeds an ACL, NMFS would reduce the ACL in the subsequent fishing year by the amount of the overage' (Section 1.1.2). This creates a three-year lag between when overfishing occurs and when catch limits are adjusted. For species like deepwater shrimp with long life spans and semelparity (Section 3.2), a three-year delay in response may allow sustained overfishing before management reacts. The document does not analyze whether a three-year lag is appropriate for long-lived species or whether faster feedback mechanisms should be required. The agency should evaluate the adequacy of the three-year moving average for stocks with different life history parameters.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
NMFS proposes to implement annual catch limits (ACL) and an accountability measure (AM) for the Hawaii deepwater shrimp and precious coral fisheries for each fishing year from 2026 to 2028. As a post-season AM, NMFS proposes to determine whether the average catch of any stock from the most recent 3 years exceeds an ACL and reduce the ACL for that stock for the subsequent fishing year by the amount of any overage. The proposed ACLs and AMs are unchanged from past measures implemented for the fisheries. This proposed rule supports the long- term sustainability of Hawaii deepwater shrimp and precious coral.
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