Posted on September 16, 2013
Written by: Shark Savers
Tags: NOAA, NMFS, National Marine Fisheries Service, HMS, lemon sharks, conservation, aggregation 

Please submit your comments to protect lemon sharks when they are at their most vulnerable – as they begin to aggregate. Please submit comments to NOAA-NMFS before the September 23, 2013 deadline.

See below for details.

marylemonphoto_72dpi_wt.pngBackground Information

In 2010, Shark Savers and a coalition of shark scientists, advocates, and concerned citizens worked with the Florida Fish and Wildlife Conservation Commission to fully protect lemon sharks within Florida State waters (extending to 3 nautical miles from shore). However their critically and ecologically important aggregation site off of Jupiter, Florida is OUTSIDE state waters. Therefore, today, lemon sharks are not protected in the states’ waters north of Florida along the Atlantic coast or in adjacent Federal waters.

The Issue

NOAA-NMFS (National Marine Fisheries Service) has proposed to open the 2014 Atlantic Shark Commercial Fishing Season (including lemon sharks) throughout their Atlantic coastal range, beginning January 1, 2014. Proposed Rule states “seasonal variation of the different species/management groups” was examined and “the proposed opening date of January 1 would allow fishermen to harvest some of the 2014 quota at the beginning of the year, when sharks are more prevalent in the South Atlantic area.”  


This means it will, again, be open season on this now vanishing lemon shark aggregation.

Before lemon sharks were protected in Florida’s waters, the Atlantic Shark Commercial Fishing Season opened on July 1, which did not interfere with either the timing of lemon shark aggregations or birth of their pups. Now, scientists, conservationists, and the recreational dive community in Florida are raising serious concerns regarding the new opening date’s timing and thus demonstrated impact on the lemon shark aggregation.


NMFS’s criteria for setting the opening of the fishing season includes “variation in seasonal distribution, abundance, or migratory patterns of the different species or management groups based on scientific and fishery information” yet in the case of the lemon sharks, these criteria have not been sufficiently thought out considering the known impact of the January 1st opening date (see below for evidence based on current biological and tagging studies).


Biological  research conducted by the Bimini Biological Field Station, directed by Dr. Steven Kessel and Dr. Samuel Gruber since 2007, has revealed that adult lemon sharks ranging from Georgia and the Carolinas down through the Florida Keys and out to the Bahamas aggregate on the coastal shelf off of Jupiter, Florida during the months of January to April, before returning to their summer home ranges. From this study, researchers report an alarming decline in redetection rates of lemon sharks since beginning in 2010 when NOAA prohibited take of the sandbar shark. On average since 2007 there has been a 10 - 15% decline per year in redetection rates, indicating harvest rates that are too high for the population to ever recover, even under maximum recovery rates for this species. The red line indicates when NMFS changed the Atlantic Coast Commercial Shark Fishing season from July 1st to January 1st. (Data source: Steve Kessel PhD and Samuel Gruber PhD, Bimini Biological Field Station -- Shark Lab) 

Additionally, reports from the recreational diving community provide further evidence that declines have occurred because of the increasingly infrequent encounters with the aggregating lemon sharks off Jupiter’s waters.

Reverting to the original July 1 opening of the Large Coastal Shark fishing season would clearly support and protect the highly vulnerable lemon shark aggregation in Florida’s waters. Therefore, Shark Savers along with a number of scientists and other NGOs, including the Bimini Biological Field Station Foundation, oppose the proposed rule that the 2014 Atlantic Shark Commercial Fishing Season open on January 1 based on its negative effect on the regional lemon shark aggregation off the coast of Jupiter, Florida. To relieve fishing pressure on this highly vulnerable, regionally-specific shark population, we recommend the fishing season opening revert to the July 1st date, when the seasonal distribution of lemon sharks is less concentrated and less easily targeted.


1. NOAA’s National Marine Fisheries Service (NMFS) is soliciting public comments with regard to a proposed rule to; again, open the Atlantic Commercial Shark Fishery on January 1, 2014.

Please submit your comments, here, letting NMFS know that you want the Atlantic Large Coastal Shark Fishing Season to revert to the opening date of July 1st, NOT January 1st, 2014. Your personal comment carries a great deal of weight, so please take a moment to send yours via the direct link above. We suggest using the following talking points that can be edited in your own words:

  • I oppose the proposed rule that the 2014 Atlantic Shark Commercial Fishing Season open on January 1 based on its negative effect on the regional lemon shark aggregation off the coast of Jupiter, Florida. To relieve fishing pressure on a highly vulnerable, breeding population of lemon sharks, I request the fishing season revert to the original opening date of July 1st, after the completion of the annual birth cycle and when the seasonal distribution of lemon sharks is less concentrated geographically.
  • Lemon sharks demonstrate specific migration patterns resulting in a predictable annual aggregation at a predictable time and place. The Jupiter lemon shark aggregation is well documented and highly publicized among the public. This means that the sharks, during the January-April season, are even more vulnerable than usual and are easily targeted by fishermen who can quickly fill their quota due to the density of the aggregation.  Theoretically and actually commercial targeting of this aggregation can completely wipe out these sharks, locally, in a matter of days to weeks.
  • The Jupiter aggregation of lemon sharks is extremely valuable to the regional SCUBA diving industry that markets the natural aggregation for dives. This aggregation has gained worldwide attention and is considered one of the best opportunities to dive, view, and photograph sharks in their natural environment. The socioeconomic benefit of the aggregation is significant to this region of Florida’s economy. The declines that are already underway have been reflected in anecdotal evidence by the recreational diving community -- diving professionals who have witnessed the aggregation, first-hand, for several years have reported much smaller numbers of lemon sharks or difficulty in finding the aggregation at all.
  • NOAA-Fisheries’ opening season criteria includes “variation in seasonal distribution, abundance, or migratory patterns of the different species or management groups based on scientific and fishery information” – I am concerned that NOAA-NMFS has not sufficiently considered the impact of a January opening date on the well-documented aggregation of lemon sharks on the narrow shelf in the South Atlantic region.
  • NMFS regulations implemented in 2006 to protect sandbar sharks have increased pressure on lemon sharks, and other large coastal shark species, along the Atlantic coast. NMFS acknowledges that “because of the mixed nature of the fishery, it is likely that any changes could affect effort and mortality for all sharks”.
  • There is evidence that the aggregating lemon shark population, off of Jupiter, Florida, is experiencing declines.  Current data analysis suggests the existing population has crashed.  While NOAA suggests that they have moved, there is no evidence to support that conclusion. Further, there is no evidence from tagging and tracking studies that lemon sharks have not tried to return to Jupiter.  Indeed some were followed remotely from the Carolinas to Jupiter in 2013. Now, since the change of the January seasonal opening date, researchers and dive operators have been alarmed by the extremely low numbers of lemon sharks found off Jupiter, and fear that this aggregation, which is believed to represent a substantial proportion of the breeding population of the eastern seaboard lemon shark population, has already been severely depleted.
  • Lemon sharks are biologically vulnerable to overfishing considering their conservative life history strategy.  A NOAA scientist, E. Cortes, stated in a publication that the lemon shark is the most vulnerable of all Large Coastal Shark species, based on several standard criteria.

2. Please share this information and the opportunity/need to submit comments to NOAA-NMFS on this important issue with friends, family, recreational divers and the shark conservation and advocacy community to increase the number of submitted comments to NOAA-NMFS before the September 23, 2014 deadline. 

The process to comment is simple and the steps for electronic submission are:
Step 1: Go to!docketDetail;D=NOAA-NMFS-2013-0112
Step 2: Click the ‘‘Comment Now!’’ icon.
Step 3: Complete the required fields and enter or attach your comments.


~ The Shark Savers Team and Bimini Biological Field Station – Shark Lab


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