Draft Recovery Plan for the Oceanic Whitetip Shark (ID453)

Peer Review Comments

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We solicited review of the Draft Recovery Plan for the Oceanic Whitetip Shark (Carcharhinus  longimanus) from four potential reviewers. Two people agreed to be reviewers and provided  reviews. Reviewer responses to the terms of reference questions compiled below are not in the  order of the reviewer identification list below. 

Reviewers (listed alphabetically): 

Dr. Melanie Hutchinson 
Senior Bycatch Mitigation Scientist
Inter-American Tropical Tuna Commission 

Dr. Yannis Papastamatiou
Associate Professor
Florida International University 

Responses to Charge Statement Questions 

Reviewer #1: 

  1. Is the threats assessment clear, accurate, and supported by the best available scientific  and commercial information (you may refer to the Draft Oceanic Whitetip Shark  Recovery Status Review Report, NMFS 2023a)? 
    Yes 
  2. Are the management units identified appropriately and justified adequately?
    Yes, but I feel recovery plan should include better validation of connectivity or lack of  between MUs (especially for the Pacific). 
  3. Are the draft recovery criteria scientifically appropriate and adequately justified for the  species given the types and level of information available?
    Yes 
  4. Are the draft recovery actions appropriate and sufficient?
    Yes
  5. Are there other recovery actions that should be considered for inclusion in the plan?
    Yes, but see above regarding connectivity of Pacific MUs. I would also add under  ecotourism another issue is poor ecotourism practices creating additional negative  feelings towards sharks. There have been several high profile bites and attacks by OWT  on tourist divers due to poorly operated tourism operations and due to the nature of this  species, I believe there will be more. Certainly not a major threat but one that is perhaps  unique to this species (there are not many pelagic sharks that feature in diving ecotourism  and this species is particularly curious towards divers). 
  6. Is the estimated time to recovery informed by the best available scientific information? Yes 
  7. Do recovery action priorities presented in the plan’s Implementation Schedule reflect a  biologically sound conservation approach for oceanic whitetip shark recovery?
    Yes 

Reviewer #2: 

  1. Is the threats assessment clear, accurate, and supported by the best available scientific  and commercial information (you may refer to the Draft Oceanic Whitetip Shark  Recovery Status Review Report, NMFS 2023a)?
    No answer. 
  2. Are the management units identified appropriately and justified adequately? No answer. 
  3. Are the draft recovery criteria scientifically appropriate and adequately justified for the  species given the types and level of information available?
    No answer. 
  4. Are the draft recovery actions appropriate and sufficient?
    No answer.  
  5. Are there other recovery actions that should be considered for inclusion in the plan?
    No answer. 
  6. Is the estimated time to recovery informed by the best available scientific information?
    No answer. 
  7. Do recovery action priorities presented in the plan’s Implementation Schedule reflect a  biologically sound conservation approach for oceanic whitetip shark recovery?
    No answer. 

Editorial Comments 

Reviewers provided various editorial comments focused on providing minor clarifications,  additional information and corrections to certain pieces of information throughout the document,  including potential typos, grammar corrections, corrections to citations, etc. These were  incorporated into the final document as appropriate. In addition, the following substantive  comments were provided and are presented by section of the document: 

1.1 ESA Listing of the Oceanic Whitetip Shark 

Reviewer 1: Regarding population structure, as cited in Camargo et al. 2016: Seems to  me that movement data also support that it is highly unlikely there is one single  population. 

1.2 Threats to the Species’ Viability and Other Stressors 
Table 1. Oceanic Whitetip Shark Threats Assessment Summary Table 

Reviewer 2 provided the following comments on the threat rankings presented in the  threats assessment table: 

Atlantic Ocean Management Unit 

  • Commercial fisheries bycatch: purse seine 
    • Severity: High - The reviewer states: “Should probably be high-moderate  if longline is high-moderate. There is only one study that has post release  survival data on OCS and they show 100% survival (Bush et al 2021 Indian Ocean).” 
    • Trend: Unknown - The reviewer states: “Why is this unknown? I thought  that purse seine fisheries had the best observer data coverage and reporting  rates. I would think it would be stable to decreasing as effort is regulated.  While longline would be stable to increasing as effort seems to be increasing.” 
  • Commercial fisheries bycatch: longline 
    • Certainty: Moderate - The reviewer states: “Per the definition of certainty  I would have classified longlines as High.” 
  • Artisanal fisheries
    • Frequency: Uncommon - The reviewer states: “I think we should define  artisanal fisheries somewhere – Also there is very little data on catch and  effort for most ‘artisanal’ fisheries so I’m curious how this was determined.” 

Eastern Pacific Management Unit 

  • Commercial fisheries bycatch: purse seine 
    • Frequency: Common - The reviewer states: “Catch rates are pretty low in  the EPO class 6 PS fishery and pales in comparison to the longline and what may be considered artisanal in some areas.” 
  • Illegal retention 
    • Frequency: Common - The reviewer states: “Where does this classification come from? IATTC has a no retention measure.” 
  • Inadequacy of fisheries regulations 
    • Severity: Moderate - The reviewer states: “Because there is very little  monitoring or enforcement across RFMOs and range states it seems like  we should use precautionary metrics here.” 

Western and Central Pacific Management Unit 

  • Illegal retention 
    • Frequency: Common - The reviewer states: “Same comment, what is the  justification here? WCPFC also has a no retention measure.” 

Other Threats or Stressors (applies to global population) 

  • Climate change 
    • Certainty: Low - The reviewer states: “I think moderate might be more  appropriate since this species is relatively restricted to the mixed layer which will be affected the most by warming oceans. Additional impacts may affect their physiological response to stress during capture since many reactions are temperature dependent.” 

3.2 Management Units 

Reviewer 1: In reference to the statement that the scope and magnitude of threats in the  Indian Ocean are potentially higher than some regions due to higher at-vessel mortality  rates in pelagic longlines and wider use and impacts of gillnets, the reviewer asks  whether it is known why. 

Reviewer 2: In reference to the statement that longline fishing mortality is likely not as  significant in the Eastern Pacific Ocean MU as in the WCPO MU, the reviewer asks  whether this could be due to the fact that the little observer data available is not  representative of the whole fleet and/or that this population has already been overfished?  The reviewer provided a link to the following report for further information: BYC-10  INF-D LL Data Summary and expansion (iattc.org) 

3.3 Objectives and Criteria 

3.3.1 Demographic Objectives and Criteria

Reviewer 2: The reviewer acknowledged the usefulness and level of detail in the  explanations of the criteria and justifications. 

Justification of Criteria 1a and 1b 

Reviewer 1: Regarding the sentence, “This apparent unifying principle of population  dynamics is independent of phenomena related to body size since the rate of population  growth is not correlated with body size,” the reviewer asks, “But metabolic ecology  shows that it is?” 

Reviewer 1: In reference to the value “K,” the reviewer asks for clarification whether this  refers to “carrying capacity.” 

3.3.2 Threats-based Objectives and Criteria 
Factor A: Present or Threatened Destruction, Modification, or Curtailment of Habitat or Range 

Reviewer 1: Reviewer asked for a citation for the following sentence: “Recent  information suggests that climate change effects (e.g., ocean warming) may negatively  affect oceanic whitetip sharks via shifts in vertical and horizontal movements and  distribution due to physiological intolerance to warming temperatures, as well as shifts in  primary prey distribution.” 

Factor D: Inadequacy of Existing Regulatory Mechanisms 

Reviewer 2: The reviewer suggested there needs to be some discussion regarding the  inadequacy of no retention measures if they are not accompanied by mandatory best  handling and release measures and increased monitoring to ensure discarded animals  have the highest probability of post-release survival. For example, gaffing, shooting,  

bludgeoning, or rolling animals through the block prior to gear recovery or removal from  gear needs to be discouraged in a meaningful way. The reviewer noted this is particularly  important in fisheries where at-vessel survival rates are high and post-release survival  rates are also high if best handling practices are used and enforced (i.e., all hook and line  and purse seine fisheries). The reviewer also noted that no retention may discourage  targeting, but it may not reduce mortality if poor practices are used. 

4.1 Recovery Action Outline 
Recovery Actions 

Reviewer 1: In reference to Population Dynamics, Recovery Action #2, “Improve  knowledge and understanding of oceanic whitetip shark distribution, movement, and  habitat use,” reviewer comments, “Can we focus on evaluating connectivity between  management zones? Atlantic is one zone so fairly easy but there are assumptions that  Pacific zones may be connected. This should be quantifiable with satellite tagging  efforts.”

Reviewer 2: In reference to Fisheries Interactions, Recovery Action #4, “Reduce fisheries  bycatch and mortality of oceanic whitetip sharks by determining and addressing the  frequency of capture, and severity of fishing interactions in commercial, artisanal, and  recreational fisheries,” the reviewer asked for clarification on whether this applies only to  U.S. waters. The reviewer also noted that what we really need are data on catch rates, an  understanding of fishing strategies that may influence catch rates, and whether or not the  animals are going to survive the interaction, so increased monitoring is of utmost  importance across their range. 

Reviewer 2: In reference to Monitoring and Reporting, the reviewer commented,  “Interaction rates are underreported in legal fisheries particularly in the EPO where  observer coverage is less than 5%. I believe enhanced monitoring of ALL fisheries is  imperative to this endeavor and deserving of an action point here outside of the IUU  point. I suggest breaking this up into two actions, ‘7. Improve species-specific monitoring  and reporting of oceanic whitetip sharks in commercial and artisanal fisheries by RFMOs  and individual countries to provide a better understanding of the effects of fishing,  improve estimates of catch and discards, and measuring progress towards recovery. 8.  Improve monitoring and international collaborations to generate estimates on magnitude  of impacts from IUU fishing’.” 

4.2 Recovery Action Narrative 
Fisheries Interactions 

4. Reduce Fisheries bycatch and mortality of oceanic whitetip sharks by determining and  addressing the frequency of capture and severity of fishing interactions in commercial, artisanal,  and recreational fisheries. 

Reviewer 1: Regarding the sentence, “This could include, for example, the potential use  of time-area closures in areas used by oceanic whitetip sharks, various deterrent methods,  research on best methods to increase at-vessel and post-release survivorship (e.g., gear  configurations), and development and implementation of species and gear-specific safe  handling and release guidelines,” the reviewer commented, “What about better  quantifying the overlap between sharks and fishing activity? This was done for the  Atlantic (well for sharks tagged in The Bahamas) but needs better representation and  remains unknown for the Pacific. Satellite tagging of sharks overlaid with ALS tracking  of boats (Quenoz et al. Nature).” 

Reviewer 2: The reviewer suggested an additional reference (Francis et al. 2023)  regarding post-release survivorship in longline fisheries. 

5. Reduce fisheries bycatch and mortality of oceanic whitetip sharks in international fisheries and  trade through enhanced international coordination and collaboration with relevant international  organizations, such as RFMOs.

Reviewer 2: Regarding the sentence, “Activities include encouraging Parties to  implement domestic regulations to comply with RFMO measures (especially retention  prohibitions), increasing observer coverage to minimum requirements, and increasing  data collection on oceanic whitetip sharks to better understand the impact of fishing on  the species,” the reviewer notes that the minimum requirements for observer coverage are  insufficient and cited Griffiths et al. 2021. 

Reviewer 2: The reviewer suggested adding the Marine Stewardship Council to the list of  example organizations with whom it would be beneficial to enhance coordination. 

Reviewer 2: With regard to the sentence, “Therefore, this recovery action includes  investing in capacity building programs in these key countries or regions, which will be  critical for reducing the main threat of overfishing on the oceanic whitetip shark,” the  reviewer noted that this is critical. 

Monitoring and Reporting

7. Improve species-specific monitoring and reporting of oceanic whitetip sharks in commercial  and artisanal fisheries by RFMOs and individual countries to provide a better understanding of  the effects of IUU fishing, improve estimates of catch and discards, and measure progress toward  recovery. 

Reviewer 2: The reviewer commented, “I think this needs to be broken into two points as  I delineated above. There needs to be data on interaction rates in all fisheries full stop.  There is a need for international collaborations to understand the scale and impacts of  IUU fishing as well. The content below also doesn’t really address IUU fishing. There are  several FAO reports on IUU fishing that will help illustrate why it is concerning for OCS  population recovery and why it needs to be addressed with international collaborations.” 

Regulatory Mechanisms and Enforcement 

8. Reduce fishing mortality of oceanic whitetip sharks through effective development,  implementation, and enforcement of international and domestic measures, such as legislation and  regulations. 

Reviewer 2: The reviewer noted that the reference to Musyl et al. 2011 is not an  appropriate reference, as the study was from scientific charters on a NOAA whiteship.  Also, in normal commercial operations, around one third of oceanic whitetip sharks are  dead at the vessel, so they really are not that robust to capture in longline fisheries and  they seem to tire easily and quickly. 

Reviewer 2: With regard to the sentence, “The United States should also work through  other international mechanisms such as CITES to ensure that any trade occurring (legal  or illegal) is not impeding recovery of the species,” the reviewer commented, “The U.S.  could also implement bans on imports of fish from nations that do not have similar or more exhaustive conservation regulations as U.S. fisheries do (as they have done for the  MMPA). 

Other Stressors 

10. Identify, evaluate, and minimize any other stressors that may be impeding recovery of  oceanic whitetip sharks. 

Reviewer 1: Regarding the example of the operation of an aquaculture pen off the coast  of Kona, Hawaii as a potential emerging stressor to oceanic whitetip sharks, the reviewer  commented, “Seems like a bigger issue here is humans being injured by sharks through  some very poor tourism practices which will counteract education efforts for this  species.” 

Reviewer 2: The reviewer commented, “What about plastics? They get entangled in  plastic, microplastics are piercing the gut cavities of the basis of their food chain. It’s a  monkey wrench but needs to be a part of the conversations on ocean health.” 

Reviewer 2: Regarding the sentence, “The species’ broad distribution and ability to move  to areas that suit their biological and ecological needs may buffer effects from climate  change,” the reviewer commented, “Or climate change can eradicate corridors between  essential habitats and areas of biological significance.”